Introduction
Why this case is interesting: This shows the thought process behind how courts interpret statutes. As an exercise, ask yourself: “How would I interpret the statute and decide this case?” Additionally, SCOTUS took this case in order to resolve a split in reasoning in a lower court. Half of the Federal Circuit Court believed this statute is subject to “equitable tolling” (see below), while the other half believed otherwise. Lastly, it’s fun to read the final opinion and then go back to listen to the oral arguments. That video is provided below.
Disclaimer: As always, my case brief is a simplified version of the opinion. Although I try my best to boil the case down to the essentials, the opinion will always be a superior, more nuanced explanation (it seems like people on all sides argue after only reading a headline!). May aim is to lay out a simplified explanation of the case (the way a law student would prepare notes before class), and if you find it interesting, you can dig deeper to be better informed. This site will never be about who is “right” or “wrong”, but only about trying to explain the arguments on both sides as clearly as possible, so that thoughtful debate can happen elsewhere. If this case interests you, there will be links to the opinion, oral arguments, and briefs from both sides below. Thanks for stopping by.
Case Brief
Facts:
- Adolfo Arellano was honorably discharged from the Navy in 1981
- He developed psychiatric disorders as result of his military service, when an aircraft carrier he was serving on collided with another ship
- 30 years after his discharge, he submitted his application for disability compensation based on psychiatric disorders that were the result of his military service
- VA assigned effective date as June 3, 2011
“Effective Date” Explained:
- the date when disability compensation payments begin
Statute (default rule):
- the effective date of award for disability compensation to a veteran “shall not be earlier” than the day on which the VA receives the application for benefits…EXCEPT…
Exception (1 of 16):
- if VA receives application within a year of the veteran’s discharge, the effective date is the day after the veteran’s discharge
Examples:
- If discharged on January 1, 2000, and application received January 1, 2015 (outside of exception)…
- payments begin February 1, 2015
- If discharged on January 1, 2000, and application received November 1, 2000 (within window of exception)…
- payments begin in December AND…
- receives payment that would have been received from January 1 – November 30 (“Retroactive Benefits”)
- What happened in this case: Discharged in 1981, and application received on June 3, 2011 (30 years later)
- Arguments:
- Arellano (P): wants the 30 years of retroactive benefits, because he claims he was too ill during the exception window to know he could apply for disability benefits
- McDonough (D, Secretary of Veterans Affairs): wants benefits to begin July 1, 2011 per the statute
- Arguments:
Issue:
- whether this exception is subject to equitable tolling (30 years of benefits for a service member hangs in the balance!)
Equitable Tolling Definition:
- “A court’s discretionary extension of a legal deadline as a result of extraordinary circumstances that prevented one from complying despite reasonable diligence throughout the period before the deadline passed.” (Black’s Law Dictionary)
Holding:
- this exception CANNOT be equitably tolled
Reasoning:
- Federal statutes of limitation are presumed to be subject to equitable tolling (however, this can be rebutted)
- The statute here contains detailed instructions for when a veteran is entitled to retroactive benefits
- given that there is such detail, it would go against the intent of the legislature to add another method of changing the effective date (through equitable tolling)
- many of the exceptions are equitable in nature, further indicating that the list is complete and exhaustive
- the legislature consistently capped the award for retroactive benefits at 1 year, indicating that it did not intend the award to be greatly increased in any way
- Arellano’s main argument: he was too ill to know he could file for benefits in the 1-year window
- Counterargument (this one’s cool!): this concern is addressed in a different exception (for disability pensions, not disability benefits). Congress therefore had a concern, and addressed it in one exception and not the other.
- Since the list of exceptions is comprehensive, Arellano’s main argument fails
- Section II-B counters Arellano’s remaining arguments; however, the above is the main argument and reasoning of this case.
Further Reading
Link to the opinion:
Oral Arguments:
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Links to Briefs of Petitioner and Respondent: