The issue in Newton v. Comm’r Soc. Sec. was whether National Guard dual status technicians qualify for the uniformed services exception, i.e., whether pensions for dual status technician service are based “wholly on service as a member of a uniformed service” under 42 U.S.C. § 415(a)(7)(A). The 3rd Circuit affirmed the District Court and held that the uniformed services exception does not cover dual status military technicians.