Wright v. Collins
24-1105
| Fed. Cir. | Aug 1, 2025Background
- Rodney Wright, a totally disabled veteran, received additional compensation for his dependent daughter B.W. under 38 U.S.C. § 1115(1)(F).
- When B.W. turned 18 and began to receive Survivors’ and Dependents’ Educational Assistance (DEA) benefits under Chapter 35, the Department of Veterans Affairs (VA) ceased Wright’s dependent compensation for her.
- B.W. exhausted her DEA benefits before finishing college; Wright then sought to resume additional compensation for B.W. as his dependent.
- The VA denied the request, citing 38 U.S.C. § 3562, which bars additional compensation for a child once DEA benefits have been elected.
- Wright appealed through the Board of Veterans' Appeals and the Veterans Court, both of which upheld the VA’s denial; he then appealed to the Federal Circuit.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether § 3562 bars additional compensation under § 1115(1)(F) after DEA elected | Bar is limited; veteran can keep prior compensation though not increases | Bar prohibits any additional compensation once DEA is elected | Section 3562 bars all additional compensation once DEA benefits commence |
| Whether the bar in § 3562 is permanent or lifts after DEA is exhausted | Bar is non-permanent; benefits should resume once DEA is exhausted | Bar is permanent under statute’s text and structure | Bar is permanent; no resumption of compensation after DEA benefits are exhausted |
| Statutory ambiguity and application of pro-veteran canon | Statute is ambiguous; ambiguity should be resolved in veteran’s favor | Statute is unambiguous; plain text controls | Statute is unambiguous; pro-veteran canon does not apply |
| Applicability of § 1115(1)(B) after DEA exhaustion | Wright claims eligibility under different subsection after DEA exhausted | Not addressed in detail; argument not preserved | Court does not decide; notes this is in conflict with subsection (F) |
Key Cases Cited
- Rowland v. Cal. Men's Colony, 506 U.S. 194 (contextual reading of statutes)
- Azar v. Allina Health Servs., 587 U.S. 566 (terms used in related statutes are presumed to have the same meaning)
- Bates v. United States, 522 U.S. 23 (courts must not add words not in the statute’s text)
- Merit Mgmt. Grp. v. FTI Consulting, Inc., 583 U.S. 366 (statutory headings provide guidance but cannot override clear text)
- Robinson v. Shell Oil Co., 519 U.S. 337 (text, context, and statutory scheme are determinative for ambiguity analysis)