Johnson v. United States Railroad Retirement Board

Nancy Johnson (plaintiff) was the wife of a former railroad employee. Beginning September 10, 1976, Johnson received a spousal annuity pursuant to the Railroad Act. The Railroad Act provided for continued spousal benefits as long as the spouse had a child under the age of 18 in her care. The Railroad Act stated that the amount of the annuity would be calculated in accordance with the method of calculating benefits under the Social Security Act (SSA). In 1981, Congress amended the SSA to lower the age for termination of children’s benefits from 18 to 16. Congress did not make a similar amendment to the Railroad Act. The United States Railroad Retirement Board (Board) (defendant) interpreted the Railroad Act and the SSA as requiring the Board to terminate children’s benefits under the Railroad Act at the age of 16 as well. The United States Courts of Appeals for the Eighth and Eleventh Circuits rejected this interpretation. The Board did not appeal to the United States Supreme Court nor request clarification from Congress on how to interpret the statutes. Rather, the Board continued to apply its interpretation at the administrative level, in direct conflict with appellate precedent. In 1986, the Board informed Johnson that she would become ineligible for a portion of her benefits once her youngest child turned 16. Johnson appealed the decision until it reached the Board, which affirmed the partial denial of her benefits. Johnson filed a class action in district court challenging the Board’s interpretation and its policy of intracircuit nonacquiescence. The district court dismissed the action because the Railroad Act vests exclusive jurisdiction to the courts of appeals. Johnson appealed.