Arellano v. McDonough
Headline: Court rejects equitable tolling for a one-year rule that limits retroactive disability pay, making it harder for veterans to get earlier post-discharge effective dates when they file late.
Holding: Section 5110(b)(1) is not subject to equitable tolling; veterans who file after the one-year post-discharge window cannot obtain the earlier post-discharge effective date.
- Prevents late filers from receiving post-discharge effective dates after the one-year window.
- Limits retroactive payments to scenarios Congress listed in the statute.
- Increases predictability for the VA in assigning benefit start dates.
Summary
Background
Adolfo Arellano served in the Navy from 1977 until his honorable discharge in 1981. About 30 years later the Department of Veterans Affairs received his application for disability compensation on June 3, 2011. A VA regional office found his psychiatric disorders were service-connected and granted benefits, giving an effective date of June 3, 2011 under the default rule that ties the start of pay to the date the VA receives a claim. Arellano asked the VA to treat his award as if he had applied within one year of discharge, saying illness had kept him from filing earlier.
Reasoning
The central question was whether the one-year exception that sets an effective date the day after discharge if a claim is filed within one year can be extended by a court-made rule called equitable tolling. The Supreme Court held that it cannot. The Justices explained that Congress wrote a detailed statute with a default rule and 16 specific exceptions, many already reflecting fairness concerns and typically capping retroactive pay at about one year. Because Congress chose that detailed list and its limits, the Court said judges may not add an open-ended equitable exception. The opinion was unanimous and written by Justice Barrett. The Court did not resolve whether the one-year rule is technically a statute of limitations, and it did not decide on other equitable doctrines like estoppel.
Real world impact
Veterans who file disability compensation claims long after discharge cannot use equitable tolling to recover many years of retroactive pay unless a listed statutory exception applies. The ruling preserves the VA's structured rules and the usual one-year retroactive cap unless Congress changes the law.
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