Supreme Court Rules Against Veterans in Disability Benefits Case
In a significant decision with potential ramifications for a vast number of veterans seeking disability benefits, the Supreme Court has ruled against two veterans who argued that the government should favor granting benefits when the evidence is ambiguous. The court, in a 7-2 decision, determined that the Veterans Court is not obligated to conduct a de novo review of evidence when evaluating a denial of benefits in cases where the evidence is closely balanced. Instead, the court can only overturn a denial if it finds a clear error in the original decision.
The case, Bufkin v. McDonough, involved two separate appeals by veterans seeking disability benefits for service-related conditions. Norman Thornton, a veteran of the first Gulf War, contended that he was entitled to a higher disability rating for post-traumatic stress disorder (PTSD). Joshua Bufkin sought PTSD benefits after his departure from the Air Force, but his claim was denied due to conflicting medical opinions regarding his eligibility.
Attorneys representing Thornton and Bufkin argued that the outcome of the case could have widespread implications for countless veterans seeking disability benefits. Numerous veterans’ groups supported the veterans’ position, asserting that the principle of granting veterans the benefit of the doubt in service-connected disability claims has been a cornerstone of the system for over a century. These groups pointed to previous congressional actions aimed at ensuring that this principle is upheld.
In 1988, Congress established the Veterans Court to review disputed benefit determinations and explicitly mandated that the scales should be tipped in favor of the veteran in close cases. However, veterans’ organizations raised concerns that the newly formed court was exhibiting excessive deference to the Department of Veterans Affairs (VA) when reviewing its decisions.
Responding to these concerns, Congress again intervened in 2002, directing the Veterans Court to "take due account" of the VA’s application of the benefit-of-the-doubt requirement. Veterans argued that Congress intended for the court to conduct a more thorough review of VA decisions, particularly given the often-unclear nature of the evidence presented in these cases.
The federal government, on the other hand, contended that the Veterans Court’s role is limited to reviewing the VA’s decision for clear errors and that it should not re-evaluate each piece of evidence. The government argued that such re-evaluation would essentially turn the Veterans Court into a primary adjudicator of claims, rather than an appellate body reviewing the VA’s decisions.
In Bufkin’s case, the Veterans Court concluded that there was no obvious error in the VA’s determination that one doctor’s assessment of whether he suffered from service-related PTSD was more comprehensive and persuasive than another’s. Bufkin’s lawyers argued that the court failed to adequately assess whether the VA had applied the benefit-of-the-doubt standard to the totality of the evidence. Bufkin’s claim of trauma stemmed from the conflict between his wife’s threats of suicide if he remained in the military and the military’s alleged response that he could either leave the service or seek a divorce.
The federal government argued that Bufkin’s case was not a close call and that the preponderance of the evidence weighed against his claim.
Similarly, in Thornton’s case, the VA found that the cumulative evidence indicated that Thornton did not warrant a higher level of disability payments. While Thornton has experienced difficulties with work and social interactions, resulting in a 50% disability rating, he argued that his rating should be higher based on one examiner’s assessment of how dissociative episodes have affected his employment.
The U.S. Court of Appeals for the Federal Circuit sided with the government, affirming that the Veterans Court had properly reviewed both determinations.
The Supreme Court’s decision effectively upholds the Federal Circuit’s ruling, establishing that the Veterans Court is not required to re-weigh evidence in close-call cases. The court’s decision suggests that the Veterans Court’s role is primarily to determine whether the VA committed a clear error in its decision-making process, rather than to conduct an independent evaluation of the evidence.
The dissenting justices argued that the majority’s decision undermines the congressional intent to ensure that veterans receive the benefit of the doubt in disability claims. They argued that the clear error standard is too deferential to the VA and that it fails to adequately protect veterans’ rights.
The Supreme Court’s decision is likely to have a significant impact on veterans seeking disability benefits. It may make it more difficult for veterans to overturn VA denials in cases where the evidence is ambiguous or conflicting. Veterans’ organizations have expressed concern that the decision will further complicate the already complex process of obtaining disability benefits and that it will disproportionately affect veterans with mental health conditions, whose claims often involve subjective evidence and conflicting medical opinions.
