October 15, 2021

Volume XI, Number 288

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October 15, 2021

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October 14, 2021

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October 13, 2021

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U.S. Supreme Court: Courts Can Review Railroad Retirement Board’s Refusal to Reopen Claims

In a 5-4 decision, the U.S. Supreme Court has ruled that federal courts can review decisions by the U.S. Railroad Retirement Board denying claimants’ requests to reopen prior benefits denials. Salinas v. U.S. R.R. Ret. Bd., No. 19-199 (Feb. 3, 2021).

Justice Sonia Sotomayor, writing for the majority, explained the relevant provision of the Railroad Retirement Act (RRA) makes judicial review available under that statute to the same extent that review is available under the Railroad Unemployment Insurance Act (RUIA). Thus, the case turned on the plain meaning of the RUIA’s judicial review provision in Section 355(f). Section 355(f) provides that any claimant, certain railway labor organizations, certain of the claimant’s employers, or “any other party aggrieved by a final decision under [§355(c)]” may obtain court review “of any final decision of the Board.”

The majority construed the broad phrase “any final decision,” as referring to “some kind of terminal event” and an agency action from which legal consequences will flow. The Court concluded that the Board’s denial of the claimant’s request to reopen his claim met those criteria: the denial was the “terminal event” in the Board’s administrative review process and it affected rights and obligations under the RRA. Thus, the Board’s denial was subject to judicial review. In reaching that decision, the majority also cited the strong presumption favoring judicial review of administrative action. Chief Justice John Roberts and Justices Stephen Breyer, Elena Kagan, and Brett Kavanaugh joined in the majority opinion.

Justice Clarence Thomas authored a dissenting opinion, which was joined by Justices Samuel Alito, Neil Gorsuch, and Amy Coney Barrett. The dissenting opinion asserted that the case should turn on the RRA’s judicial review provision, which references the RUIA to explain how to obtain judicial review, but separately defines what may be reviewed.

The Court’s decision resolves a long-standing split among the Circuit Courts of Appeals on this issue.

Jackson Lewis P.C. © 2021National Law Review, Volume XI, Number 39
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About this Author

Associate

Lindsey H. Chopin is an Associate in the New Orleans, Louisiana, office of Jackson Lewis P.C. and a member of the firm’s ERISA Complex Class Action, Employee Benefits and Class Action groups.

Ms. Chopin focuses her practice on the defense of complex ERISA class-actions filed against public and private single employer ERISA plan sponsors and fiduciaries, as well as multi-employer plans and fiduciaries and ERISA plan services providers.  She has litigated a wide variety of class action claims, including 401(k) fee claims,...

504-208-1755
Principal

Stacey C.S. Cerrone is a Principal in the New Orleans, Louisiana, office of Jackson Lewis P.C. Her practice focuses on representing employers in workplace law matters, including preventive advice and counseling.

Practices

  • Employee Benefits

Admitted to Practice

  • 5th Circuit Court of Appeals, 1998
  • 6th Circuit Court of Appeals, 2014
  • Louisiana - E.D. La., 1999
  • Louisiana - M.D. La., 1998
  • Louisiana - W.D. La., 1998
  • Louisiana, 1998
504-208-1755
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