605 U.S. 360
U.S.2025Background
- The Barring Act (31 U.S.C. §3702) sets a 6-year statute of limitations for most claims against the government but has an exception if "another law" establishes a separate settlement mechanism.
- In 2002, Congress created Combat-Related Special Compensation (CRSC) for veterans with combat-related disabilities, administered by the military Secretaries under 10 U.S.C. §1413a.
- Retired veterans usually must waive some retirement pay to receive VA disability benefits, but CRSC permits special compensation for waived pay due to combat-related disability.
- Simon Soto, a Marine Corps veteran, applied for CRSC in 2016 and received only six years of retroactive pay due to the Barring Act, prompting him to file a class action.
- The district court sided with Soto, holding the Barring Act’s 6-year limitation does not apply to CRSC claims; the Federal Circuit reversed, holding the CRSC statute did not provide a separate settlement mechanism.
- The Supreme Court granted certiorari to resolve whether the CRSC statute is "another law" that displaces the Barring Act for CRSC claims.
Issues
| Issue | Soto's Argument | U.S. Argument | Held |
|---|---|---|---|
| Does the CRSC statute confer authority to settle CRSC claims, displacing the Barring Act’s 6-year limitations period? | CRSC statute is a comprehensive scheme granting the Secretary authority to determine both eligibility and amount due, thus providing a separate settlement mechanism not subject to the Barring Act. | CRSC statute does not use the term "settle" or set a limitation period; only statutes with explicit settlement or limitations language displace the Barring Act. | Yes; the CRSC statute’s process for determining eligibility and amount due constitutes a separate settlement mechanism, displacing the Barring Act's procedures and limitations period. |
Key Cases Cited
- Illinois Surety Co. v. United States ex rel. Peeler, 240 U.S. 214 (1916) (defining “settlement” in government claims context as administrative determination of amount due)
- Department of Agriculture Rural Development Rural Housing Service v. Kirtz, 601 U.S. 42 (2024) (no "magic words" needed to create statutory waiver or confer authority)
- Winkelman v. Parma City School Dist., 550 U.S. 516 (2007) (reviewing statutory scheme as a whole to determine conferred authority)
- FAA v. Cooper, 566 U.S. 284 (2012) (Congress need not use specific language to waive sovereign immunity)