Supreme Court Upholds VA Court Ruling Denying Veterans’ Benefits
The U.S. Supreme Court has ruled against two military veterans who argued that their disability claims were wrongly denied, even though the evidence in their cases was evenly split.
In a 7-2 decision, the Court held that the U.S. Court of Appeals for Veterans Claims is not required to independently reassess how the Department of Veterans Affairs applies the long-standing “benefit-of-the-doubt” rule, according to Military.com. That rule has long stated that when evidence for and against a claim is nearly equal, the decision should favor the veteran.
Writing for the majority, Justice Clarence Thomas stated that neither the Veterans Court nor the Federal Circuit was obligated to re-apply that rule in the disputed cases. Instead, he explained, the Veterans Court’s responsibility was simply to review the decisions made by VA claims adjudicators and the Board of Veterans’ Appeals for errors.
“We hold that the Veterans Court must review the VA’s application of the rule the same way it would any other determination — by reviewing legal issues [from the beginning] and factual issues for clear error,” Thomas wrote.
The case, Bufkin v. Collins, involved two veterans who challenged the VA’s determinations.
Joshua Bufkin, a former Air Force servicemember who served from 2005 to 2006, filed a later disability claim for PTSD. Bufkin had struggled during his military training, attributing his difficulties to severe marital stress at the time. VA doctors, however, disagreed over both his diagnosis and whether his symptoms were related to service, leading to the rejection of his claim.
Norman Thornton, an Army veteran who served from 1988 to 1991 and deployed during the Persian Gulf War, initially received a 10% disability rating for PTSD, later increased to 50%. Thornton appealed again, seeking a higher rating — but the Board ruled the evidence did not justify an increase.
Although both men argued that the evidence in their cases was at least evenly balanced — meaning the benefit-of-the-doubt rule should have applied — the Veterans Court reviewed their appeals only for administrative error. The Federal Circuit affirmed that the Veterans Court was not obligated to perform its own balance-of-evidence review.
The veterans then appealed to the Supreme Court, contending that Congress intended veterans to directly receive any reasonable doubt in their favor. Thomas rejected that argument, writing that the challengers failed to demonstrate a legal basis requiring such review.
“After closely examining the way in which the VA conducts the approximate balance inquiry [of benefit-of-the-doubt evidence], we conclude it is a predominantly factual question and thus subject to clear-error review,” Thomas wrote.
Justices Ketanji Brown Jackson and Neil Gorsuch dissented. Jackson argued that the majority decision undercuts protections Congress designed for veterans.
Jackson wrote that veterans are entitled to have “any reasonable doubt on a material issue” resolved in their favor. She criticized the ruling, stating:
“The court today concludes that Congress meant nothing when it inserted [into law,] in response to concerns that the Veterans Court was improperly rubberstamping the VA’s benefit-of-the-doubt determinations and also that the Veterans Court is not obliged to do anything more than defer to those agency decisions,” Brown wrote. “I respectfully dissent.”
The Supreme Court ultimately ruled that the benefit-of-the-doubt rule remains within the VA’s purview, and that the Veterans Court is generally not required to apply it independently unless there is clear evidence of error.
With President Donald J. Trump now serving his second term and continuing to prioritize veterans’ care and service-connected benefits, the ruling is expected to spark renewed congressional pressure for greater accountability and transparency inside the VA system.