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Law School Case Brief

Johnson v. United States R.R. Ret. Bd - 297 U.S. App. D.C. 82, 969 F.2d 1082 (1992)


Under the law of the District of Columbia, when an agency interprets a statute other than that which it has been entrusted to administer, its interpretation is not entitled to deference. The Court of Appeals for the District of Columbia has repeatedly held that when an agency interprets a general statute rather than its organic statute, the court is not bound by its construction, even if reasonable, but should engage in de novo review, guided by congressional intent.


Plaintiff, the wife of a former railroad employee filed a complaint against defendant  United States Railroad Retirement BoardBoard) because the Board denied benefits to the plaintiff’s children after they turned 16 years old. Although the Railroad Retirement Act of 1974 stated that the children were entitled to benefits until they turned 18, defendant Board relied on an opinion issued by a circuit court of appeals in denying the benefits. The district court dismissed the action for lack of jurisdiction. Plaintiff appealed.


Was the defendant Board’s denial of benefits to plaintiff’s children proper?




The court reversed and remanded the action with directions to award the wife a spouse's annuity for the period that began with the termination of her annuity and which ended when her youngest child turned 18. The court of appeals found that the Board's application was a patently unreasonable interpretation of the law and that the Board was not entitled to deference because it was not interpreting its governing statute alone, but rather the relationship between the Act and the Social Security Act.

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