598 U.S. 1
U.S.2023Background
- Adolfo Arellano served in the Navy from 1977 to an honorable discharge in 1981 and applied for VA disability compensation in June 2011 (about 30 years later).
- A VA regional office granted service-connection for psychiatric disorders and set the award's effective date as June 3, 2011 (the date the VA received his claim) under 38 U.S.C. §5110(a)(1).
- Arellano sought an effective date the day after his 1981 discharge under §5110(b)(1) and argued that the 1‑year filing window in §5110(b)(1) should be equitably tolled because his mental illness prevented earlier filing.
- The Board of Veterans’ Appeals denied tolling; the Court of Appeals for Veterans Claims affirmed; the en banc Federal Circuit affirmed (divided on rationale).
- The Supreme Court granted review and held that §5110(b)(1) is not subject to equitable tolling because the statute’s text and structure rebut the presumption that equitable tolling applies.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether §5110(b)(1)’s 1‑year rule for an effective date following discharge is subject to equitable tolling | Arellano: §5110(b)(1) is a simple time limit; traditional equitable tolling should allow relief where disability prevented timely filing | Government: The provision is not (necessarily) a statute of limitations and, even if it were, the statutory text and structure rebut the Irwin presumption | Court: §5110(b)(1) is not subject to equitable tolling; presumption rebutted by §5110’s text and structure |
| Whether the Court must treat §5110(b)(1) as a statute of limitations to decide tolling | Arellano: Irwin presumption applies to time limits like this one | Government: §5110(b)(1) caps recovery rather than extinguishes claims; presumption may not apply | Court: Did not decide whether it is a limitations statute; assumed arguendo and concluded the presumption is rebutted by statutory scheme |
Key Cases Cited
- Lozano v. Montoya Alvarez, 572 U.S. 1 (presumption that statutes of limitations are subject to equitable tolling)
- Irwin v. Department of Veterans Affairs, 498 U.S. 89 (presumption that federal statutes of limitations permit equitable tolling)
- United States v. Brockamp, 519 U.S. 347 (express listing of exceptions with substantive limits rebuts equitable tolling)
- United States v. Beggerly, 524 U.S. 38 (when Congress considered equitable concerns and limited relief, additional tolling is unwarranted)
- John R. Sand & Gravel Co. v. United States, 552 U.S. 130 (equitable doctrines cannot override statutory scheme)
- Young v. United States, 535 U.S. 43 (context where an express tolling provision can supplement equitable tolling)
- King v. St. Vincent’s Hospital, 502 U.S. 215 (benefits provisions construed in beneficiaries’ favor)