Youngman v. Dept. Of Veterans Affairs, 699 F.3d 1301

Veteran Richardson was awarded about $350,000 in accrued benefits in May 2005, effective March 10, 1986.
Youngman was appointed as fiduciary and later curator for Richardson after the prior fiduciary resigned.
Richardson died in July 2005 after filing petitions seeking payment of accrued benefits.
VA withheld payment pending Youngman’s appointment; Youngman sought to distribute funds to Richardson’s heirs.
Federal Circuit previously held Youngman lacked standing to pursue the claim as successor in interest.
The case centers on whether a veteran’s fiduciary may receive accrued benefits unpaid at death under statutory schemes.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Can a veteran's fiduciary receive accrued benefits unpaid at death?	Youngman argues §5502 allows fiduciary rights beyond §5121.	Secretary argues §5121(a) restricts distribution to statutorily listed payees, not fiduciaries.	Fiduciary has no standing to receive unpaid accrued benefits.
Relation between §5121(a) and §5502 in accrued benefits after death?	§5502 independent of §5121, allowing fiduciary to receive funds for the veteran's use.	§5121 controls distribution, and §5502 does not override its limits.	§5121 controls; fiduciary may not bypass its limits.
Whether interpreting §5502 to avoid §5121 results in an absurd outcome?	Interpreting to favor fiduciary avoids inequity where there are no qualifying heirs.	Congress intended restrictions on who may receive accrued benefits at death.	No exception to §5121; no standing for fiduciary.

Richard ex rel. Richard v. West, 161 F.3d 719 (Fed. Cir. 1998) (death limits recipients of disability compensation to §5121 categories)
Richardson v. Nicholson, 476 F.3d 883 (Fed. Cir. 2007) (addressed prior standing of fiduciary in similar context)