Salinas v. Railroad Retirement Bd., 592 U.S. 188

Background

Salinas, a former railroad employee, suffered workplace injuries and filed multiple Railroad Retirement Act (RRA) disability applications; his 2006 application was denied and he missed the statutory reconsideration deadline.
In 2013 Salinas filed a fourth application and was granted benefits effective in 2010/2012; he then sought reconsideration of amount/start date.
On appeal Salinas asked the Board to reopen the 2006 denial, arguing the Board had not considered certain contemporaneous medical records.
The Board (and its Bureau) denied reopening as untimely under its regulation requiring new and material evidence within four years (20 C.F.R. §261.2(b)); the Board informed Salinas he could seek judicial review.
The Fifth Circuit dismissed Salinas’s petition for lack of jurisdiction, joining most circuits that held Board refusals to reopen are not judicially reviewable.
The Supreme Court granted certiorari to resolve the circuit split and decided whether a Board refusal to reopen is a "final decision" subject to judicial review under the RRA (via incorporation of the RUIA §355(f)).

Issues

Issue	Plaintiff's Argument (Salinas)	Defendant's Argument (Board)	Held
Whether a denial of reopening is a "final decision" under 45 U.S.C. §355(f) (as incorporated into the RRA by §231g)	Reopening denial consummates agency review and has legal consequences; thus it is an "any final decision" and reviewable	The phrase should be read to mean only "final decisions under §355(c)" (i.e., determinations awarding/denying benefits), so reopening refusals fall outside review	Held: denial to reopen is a "final decision" under §355(f) and thus reviewable; §355(f)’s broad "any final decision" controls
Whether ambiguity (if any) should be resolved for reviewability	Presumption favors judicial review of administrative action; ambiguity must be resolved in claimant's favor	The statutory structure and cross-references show §355(f) and §355(c) are coextensive, rebutting the presumption	Held: the presumption applies; structural arguments do not overcome the plain text and presumption, so reviewability stands
Whether precedents (Califano; Your Home) bar review of reopening denials	Those precedents are distinguishable because their review provisions contained textual limits (e.g., "made after a hearing") or narrower statutory scopes	Califano and Your Home support non-reviewability of reopening denials and should apply here	Held: Califano and Your Home are distinguishable on text and statutory scope; unlike §405(g), §355(f) contains no analogous limitation, so the precedents do not preclude review
Standard and scope of review for reopening denials	Judicial review must be available but will be deferential	Allowing review will improperly inject courts into discretionary, grace-based agency decisions	Held: Review is available but limited; reopening denials are discretionary and subject to abuse-of-discretion review under Board regulations (20 C.F.R. §261.11)

Key Cases Cited

Smith v. Berryhill, 587 U.S. _ (discusses meaning of "final decision" and two-part Bennett test)
Bennett v. Spear, 520 U.S. 154 (two-part test for final agency action)
Mach Mining, LLC v. EEOC, 575 U.S. 480 (strong presumption favoring judicial review of administrative action)
Kucana v. Holder, 558 U.S. 233 (presumption that Congress legislates against precluding review)
Hawkes Co. v. Army Corps of Engineers, 578 U.S. 590 (agency action from which legal consequences flow qualifies as final)
Califano v. Sanders, 430 U.S. 99 (refusal to reopen Social Security determinations not reviewable under §405(g))
Your Home Visiting Nurse Servs., Inc. v. Shalala, 525 U.S. 449 (refusal to reopen Medicare intermediary decision not reviewable)
ICC v. Locomotive Engineers, 482 U.S. 270 (noting deferential treatment of discretionary agency actions)
Roberts v. Railroad Retirement Bd., 346 F.3d 139 (5th Cir. precedent holding reopening refusals nonreviewable; part of the circuit split resolved here)