Supreme Court Upholds VA Court Ruling Denying Veterans’ Benefits
The U.S. Supreme Court delivered a significant ruling this week, siding against two veterans who argued that their disability claims were wrongfully denied even though the evidence in their cases appeared evenly balanced.
In a 7–2 decision, the Court affirmed that the U.S. Court of Appeals for Veterans Claims is not obligated to independently reapply the Department of Veterans Affairs’ “benefit-of-the-doubt” standard in most cases. Under that rule, the VA must approve claims when the supporting and opposing evidence is essentially equal, according to reporting from Military.com.
Writing for the majority, Justice Clarence Thomas made clear that neither the Veterans Claims Court nor the Federal Circuit — which upheld the earlier ruling — were required to conduct a fresh benefit-of-the-doubt evaluation. Instead, Thomas explained that the veterans court’s responsibility is to review the case file for legal mistakes made by VA adjudicators or the Board of Veterans’ Appeals, not to relitigate the factual disputes.
“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, centered on claims brought by two former service members. Joshua Bufkin, who served in the Air Force from 2005 to 2006, applied for disability benefits about seven years after leaving active duty. He attributed his service-related struggles to severe marital stress, claiming that his training as a military policeman became impossible after his wife allegedly threatened suicide if he remained in uniform. He ultimately requested a hardship discharge.
When he later sought VA healthcare and benefits, Bufkin maintained that his mental-health struggles were linked to his service. But conflicting diagnoses and disagreements among VA physicians over whether he suffered from PTSD — and whether it was service-connected — led to his claim being denied.
The second plaintiff, Norman Thornton, served in the Army from 1988 to 1991 and deployed to the Persian Gulf during Operation Desert Storm. He initially received a 10% disability rating for PTSD, later increased to 50%. Thornton appealed that rating, insisting his condition warranted a higher percentage.
In both cases, the Board of Veterans’ Appeals sided with the original determinations, concluding that Bufkin’s evidence was contradictory and that Thornton’s documentation did not justify a higher rating.
The Veterans Court later reviewed the cases and found no errors in the adjudication process — yet did not perform a benefit-of-the-doubt review. The Federal Circuit affirmed, holding that such additional review was not legally required.
Before the Supreme Court, the plaintiffs argued that Congress clearly intended for veterans to receive the benefit of the doubt in disputed cases. But Justice Thomas rejected that interpretation, emphasizing that the veterans court cannot overturn a decision unless there is “clear error.”
“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.
Two justices dissented — Ketanji Brown Jackson and Neil Gorsuch. Jackson argued that the majority’s interpretation effectively guts Congress’s intent.
She wrote that veterans are entitled to have “any reasonable doubt on a material issue” resolved in their favor, criticizing the ruling as a step backward in oversight. Jackson stated that “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. I respectfully dissent.”
Ultimately, the Court accepted the case to determine whether the Veterans Court must evaluate the VA’s use of the benefit-of-the-doubt doctrine beyond checking for errors. The majority concluded that it generally does not.