Reynolds v. United States

Background

An honorably discharged veteran who served in the Spanish-American War was confined as insane at St. Elizabeths Hospital from 1911 until his discharge in 1930. The Veterans’ Bureau and the Bureau of Pensions had credited $4,036 to the hospital for his care. On discharge the hospital kept advances for clothing and then applied $3,259.17 against charges for board. The veteran protested and sought payment, and the Court of Claims dismissed his suit. A 1924 law and a 1926 change added a rule that a veteran’s pension “shall not be subject to deduction” for board while hospitalized.

Reasoning

The key question was whether that 1926 proviso barred the hospital from keeping pension money for board charges and whether the veteran could recover funds withheld. The Court found that St. Elizabeths counted as a hospital facility under the Veterans’ Bureau, that the veteran met the statute’s requirements, and that the proviso clearly protected his pension from deduction while he was hospitalized. The Court rejected the government’s argument that the proviso should not cover charges that began before July 2, 1926, because the actual deduction occurred at discharge after the proviso took effect. For those reasons the Court reversed the lower court and directed judgment for the veteran.

Real world impact

The decision prevents government hospitals using a veteran’s pension to pay for board while the veteran is hospitalized and lets veterans recover pension funds wrongfully withheld at discharge. It clarifies that the statutory protection can cover continuous charges that span the proviso’s effective date.

Dissents or concurrances

Justices Stone and Cardozo dissented. They disagreed with the majority’s conclusions.