Salinas v. United States Railroad Retirement Board
 | |
| Salinas v. United States Railroad Retirement Board | |
| Term: 2020 | |
| Important Dates | |
| Argument: November 2, 2020 Decision: February 3, 2021 | |
| Outcome | |
| Reversed and remanded the 5th Circuit's ruling | |
| Vote | |
| 5-4 | |
| Majority | |
| Sonia Sotomayor • Chief Justice John G. Roberts • Stephen Breyer • Elena Kagan • Brett Kavanaugh | |
| Dissenting | |
| Clarence Thomas • Samuel Alito • Neil Gorsuch • Amy Coney Barrett | |
Salinas v. United States Railroad Retirement Board is a U.S. Supreme Court case involving the scope of judicial review of actions taken by administrative agencies. The court ruled that a choice by the U.S. Railroad Retirement Board not to reopen a decision to deny Manfredo Salinas benefits was a final agency action subject to judicial review. In the majority opinion, the court said that review of agency reopening decisions will be limited to weighing whether the agency decision was an abuse of discretion.[1]
The case was argued before the Supreme Court of the United States on November 2, 2020, during the court's October 2020-2021 term. The case came on a writ of certiorari to the United States Court of Appeals for the 5th Circuit.[2]
You can review the lower court's opinion here.[6]
Why it matters: The decision allows courts to review agency decisions not to reopen cases, which expanded the definition of final agency actions open to judicial review. The majority opinion says that review will be limited and that courts will only be able to review agency decisions to grant or deny reopening for abuses of discretion.[1] "The ruling represents another in a string of recent decisions rebuffing agencies’ efforts to shield their decisions from judicial review," according to Sam Callahan and Allon Kedem, writing for SCOTUSblog.[7]
Timeline
The following timeline details key events in this case:
- February 3, 2021: The U.S. Supreme Court ruled that the denial of a request to reopen a benefits determination was a final agency decision subject to judicial review.
- November 2, 2020: Oral argument was heard.
- January 10, 2020: The U.S. Supreme Court agreed to hear the case.
- August 15, 2019: Manfredo Salinas filed a petition with the U.S. Supreme Court.
- April 17, 2019: The United States Court of Appeals for the 5th Circuit dismissed Manfredo Salinas' petition for review.
Background
On February 28, 2006, Manfredo Salinas applied for a disability annuity with the United States Railroad Retirement Board's Disability Benefits Division.[8] The application was denied on August 28, 2006. On November 30, 2006, Salinas petitioned the Board to reconsider his application. The Board's Reconsideration Section denied the request, finding that Salinas had not provided a suitable cause for filing the request outside of the necessary time frame for consideration. Salinas did not pursue an additional administrative appeal. The Board's denial became a finalized decision on February 9, 2007.[6]
On December 26, 2013, Salinas filed a new application for a disability annuity. The Board granted the annuity. Salinas appealed the annuity's beginning date and amount. On February 15, 2015, during the appeal, Salinas requested that the Board reopen all of its decisions on his prior applications. A Board hearing officer conducted an oral hearing and found that Salinas' 2006 application was outside of the four-year time frame under the Board's regulations for reopening applications based on administrative error or new and material evidence. Salinas petitioned the 5th Circuit to review the Board's decision. The 5th Circuit dismissed the petition, holding that it lacked jurisdiction to review the Board's decision not to reopen Salinas' earlier case.[6]
Questions presented
The petitioner presented the following questions to the court:
| Questions presented: |
Oral argument
Audio
Audio of oral argument:[9]
Transcript
Outcome
The court reversed the 5th Circuit's decision and sent the case back to that court for further proceedings with a 5-4 vote in favor of Salinas. The majority opinion was written by Justice Sonia Sotomayor and joined by Chief Justice John Roberts and Justices Stephen Breyer, Elena Kagan, and Brett Kavanaugh. Justice Clarence Thomas filed a dissenting opinion joined by Justices Samuel Alito, Neil Gorsuch, and Amy Coney Barrett.[1]
Opinions
Opinion of the court
Justice Sonia Sotomayor delivered the majority opinion stating, "This case asks whether the Board’s refusal to reopen the prior denial of benefits is subject to judicial review. The Court holds that it is."[1] She cited interpretations of the Administrative Procedure Act (APA) and argued that the Board's refusal to reopen the case was an example of agency action that "mark[s] the consummation of the agency’s decisionmaking process" and " is one by which rights or obligations have been determined."[1] She also argued that courts should resolve any ambiguity about whether an agency decision was final in favor of judicial review.[1]
Dissenting opinion
Justice Clarence Thomas wrote a dissenting opinion arguing that the court should have applied the 1999 precedent from Your Home Visiting Nurse Services, Inc. v. Shalala to rule that an agency decision not to reopen a decision was not a final agency action, and thus not subject to judicial review.[1] He argued that the language of the statute at issue in the case was clear enough to prevent judicial review of the Board's decision not to reopen its consideration of Salinas' earlier benefits requests.[1]
Text of the opinion
Read the full opinion here.
Commentary about the case
Post-decision commentary
Sam Callahan and Allon Kedem, writing for SCOTUSblog, described the case in the following way: "The ruling represents another in a string of recent decisions rebuffing agencies’ efforts to shield their decisions from judicial review."[7] They added, "With few exceptions, the court in recent years has generally interpreted judicial-review statutes to hold agencies accountable by permitting courts to review their decisions. Wednesday’s ruling in Salinas’ favor continues the trend."[7]
See also
External links
- Search Google News for this topic
- U.S. Supreme Court docket file - Salinas v. United States Railroad Retirement Board (petitions, motions, briefs, opinions, and attorneys)
- SCOTUSblog case file for Salinas v. United States Railroad Retirement Board
Footnotes
- ↑ 1.0 1.1 1.2 1.3 1.4 1.5 1.6 1.7 U.S. Supreme Court, "Salinas v. United States Railroad Retirement Board," February 3, 2021
- ↑ 2.0 2.1 2.2 SCOTUSblog, "Salinas v. United States Railroad Retirement Board," accessed January 14, 2020
- ↑ 3.0 3.1 Supreme Court of the United States, "19-199 Salinas v. Railroad Retirement Board," accessed January 14, 2020
- ↑ 4.0 4.1 United States Code, "45 U.S.C. § 355," accessed January 14, 2020
- ↑ 5.0 5.1 United States Code, "45 U.S.C. § 231g," accessed January 14, 2020
- ↑ 6.0 6.1 6.2 United States Court of Appeals for the 5th Circuit, "Salinas v. U.S. R.R. Ret. Bd.," decided April 17, 2019
- ↑ 7.0 7.1 7.2 SCOTUSblog, "Divided court favors judicial review of agency decision on railroad worker benefits," February 5, 2021
- ↑ United States Code, "45 U.S.C. § 231a," accessed January 14, 2020
- ↑ Supreme Court of the United States, "Oral Argument - Audio," accessed November 9, 2020
