Henderson v. Shinseki, 131 S. Ct. 1197

VA benefits adjudication is a two-step process: regional office decision, then de novo Board review; Board decisions are reviewable by the Veterans Court via a 120-day appeal window (§7266(a)).
Henderson missed the 120-day deadline by 15 days; he sought equitable tolling in the Veterans Court.
Bowles v. Russell held a civil appeal deadline to be jurisdictional; the Veterans Court and the issue here involve administrative review, not ordinary Article III appeals.
The Federal Circuit held Bowles compelled jurisdictional treatment of the 120-day deadline, dismissed Henderson’s untimely appeal.
The Court held the 120-day deadline is not jurisdictional but is a claim-processing rule, and equitable tolling may apply on remand.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the 120-day deadline is jurisdictional	Henderson: Bowles governs; deadline is jurisdictional	Shinseki: Bowles controls; deadline is jurisdictional	Not jurisdictional; treated as claim-processing rule
Whether Congress clearly intended the deadline to be jurisdictional	Henderson: no clear indication to treat as jurisdictional	Government: Bowles-like intent implied by statute	Congress did not clearly make it jurisdictional
Whether the deadline can be equitably tolled absent jurisdictional status	Henderson: equitable tolling may apply	Government: tolling depends on jurisdictional framing	To be considered on remand; Court does not decide tolling here

Bowles v. Russell, 551 U.S. 205 (U.S. 2007) (deadline not excused in ordinary civil appeals; jurisdictional in that context)
Arbaugh v. Y & H Corp., 546 U.S. 500 (U.S. 2006) (readily administrable bright-line rule for jurisdictional determinations)
Kontrick v. Ryan, 540 U.S. 443 (U.S. 2004) (limits on labeling rules jurisdictional; context matters)
Bowen v. City of New York, 476 U.S. 467 (U.S. 1986) (review of Social Security disability benefits not jurisdictional)