Martin v. United States
133 Fed. Cl. 248
| Fed. Cl. | 2017Background
- Plaintiff Kari L. Martin served as a Navy nurse (1995–2014) and deployed to Camp Bastion, Afghanistan (Oct 2010–Apr 2011), where she treated combat trauma patients and later developed PTSD; she was placed on the TDRL and discharged in 2014.
- Martin applied for Combat-Related Special Compensation (CRSC) under 10 U.S.C. § 1413a, asserting her PTSD was incurred "while engaged in hazardous service."
- DoD guidance (DD Form 2860 and the Financial Management Regulation) defines "hazardous service" and requires a documented causal nexus between hazardous service and the disability; the 2008 DD Form 2860 added language requiring exposure to actual or simulated armed conflict.
- The CRSC Board denied Martin’s claim for lack of specific combat-related events causally linked to her PTSD; the BCNR affirmed, concluding hazardous service requires a combat-related nexus and that location alone (working in a combat zone) is insufficient.
- Martin sued in the Court of Federal Claims seeking declaration that BCNR/DoD misinterpreted § 1413a(e)(2)(B) and remand to determine CRSC entitlement; cross-motions for judgment on the administrative record followed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether DoD’s definition of "hazardous service" (requiring a combat-related nexus/exposure to actual or simulated armed conflict) is lawful under Chevron | Martin: DoD’s definition strays from the statute’s plain meaning and Congress intended "hazardous service" to cover injuries distinct from "armed conflict" or "simulating war" categories; DoD’s change is arbitrary and effectively eliminates subsection (B) | U.S.: Congress delegated authority to DoD to prescribe criteria; DoD’s interpretation is reasonable, consistent with statute’s combat-related purpose, and entitled to Chevron deference | Court: Chevron applies; Congress left definition to DoD and DoD’s interpretation is reasonable and not arbitrary or capricious; held for defendant |
| Whether Martin’s nursing in a combat zone qualifies as hazardous service absent a specific combat-related causal event | Martin: Working in Camp Bastion exposed her to combat hazards and caused PTSD; location and duties there suffice | U.S.: Mere performance of normally non-hazardous duties in a combat zone without a specific causal nexus does not meet DoD criteria; location alone creates an untenable, overbroad class | Court: Location alone is insufficient; BCNR reasonably required a specific combat-related nexus; Martin’s record did not establish that nexus |
Key Cases Cited
- Stine v. United States, 92 Fed. Cl. 776 (discussing military retirement and VA disability distinctions)
- Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837 (establishing two-step deference framework)
- United States v. Mead Corp., 533 U.S. 218 (delegation and when agency interpretations receive Chevron deference)
- Hymas v. United States, 810 F.3d 1312 (Fed. Cir. 2016) (deference to agency policy choices in CRSC context)
- Bannum, Inc. v. United States, 404 F.3d 1346 (Fed. Cir. 2005) (standard for judgment on the administrative record)
- A & D Fire Prot., Inc. v. United States, 72 Fed. Cl. 126 (2006) (burden and review on administrative-record motions)