Bufkin v. Collins, 604 U.S. 369

The Department of Veterans Affairs (VA) uses the "benefit-of-the-doubt" rule, granting veterans favorable consideration when evidence in service-related disability claims is in "approximate balance."
Petitioners Bufkin and Thornton, veterans with PTSD claims, challenged unfavorable VA benefit determinations, arguing the benefit-of-the-doubt rule was misapplied.
Their claims were denied by the Board of Veterans’ Appeals after careful factual evaluation.
The Veterans Court reviewed the denials, affirming the Board’s decisions under a clear-error standard for fact-finding.
Petitioners argued to the Federal Circuit that the Veterans Court should instead review VA’s application of the benefit-of-the-doubt rule de novo.
The Supreme Court granted certiorari to decide the standard of review the Veterans Court must use for VA’s benefit-of-the-doubt determinations.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standard for reviewing VA's "approximate balance" determinations	Veterans Court must review the entire record de novo and independently determine balance of evidence	VA’s determination is predominantly factual, so review is for clear error	VA’s approximate balance determination is factual/mixed, reviewed for clear error
Whether §7261(b)(1) creates a new standard of review	"Take due account" imposes a new, non-deferential (de novo) standard for appellate review	§7261(b)(1) simply incorporates existing standards in §7261(a); no new standard	No new standard; existing standards (clear error for fact, de novo for law) apply
Comparison to probable cause and sufficiency determinations	Approximate balance is like probable cause—a mixed question reviewed de novo	Probable cause involves substantial legal work/constitutional standards; VA’s determination is more factual	Approximate balance review is fact-intensive, so not analogous; reviewed for clear error
Addressing superfluity/canonical interpretation	Without new meaning, §7261(b)(1) is superfluous	Amendment simply makes explicit a pre-existing duty; some redundancy allowed	No competing interpretation avoids redundancy; clear-error standard affirmed

United States v. Detroit Timber & Lumber Co., 200 U.S. 321 (clarifies that the syllabus is not part of the opinion)
Shinseki v. Sanders, 556 U.S. 396 (interprets the scope of review for prejudicial error under a parallel provision)
U.S. Bank N.A. v. Village at Lakeridge, LLC, 583 U.S. 387 (discusses standards for review of mixed questions of law and fact)
Ornelas v. United States, 517 U.S. 690 (sets de novo review for probable cause, contrasted with the more factual VA standard)
Kentucky v. King, 563 U.S. 452 (details principles for review of probable cause)
Jackson v. Virginia, 443 U.S. 307 (sets standard for sufficiency-of-evidence appellate review)
Anderson v. Bessemer City, 470 U.S. 564 (explains deference to trial court factual findings)