Hernandez v. Veterans' Administration
Headline: Conscientious objectors denied veterans’ education benefits get their case back as the Court vacates the appeals judgment and allows courts to hear constitutional challenges to benefit denials.
Holding:
- Allows courts to hear constitutional challenges to veterans’ benefits denials by conscientious objectors.
- Vacates the appeals court judgment and sends the case back for further consideration.
- Keeps open First and Fifth Amendment claims against benefit‑disqualification rules.
Summary
Background
The petitioners are Class I‑O conscientious objectors who completed alternative civilian service under the Selective Service rules and then applied for education benefits under the Veterans’ Readjustment Benefits Act of 1966. The Veterans’ Administration denied their applications because the statutes at issue treat a person who performed alternative civilian service as not having “served on active duty,” and therefore not an “eligible veteran.” The petitioners sued, claiming the benefit rules discriminated against conscientious objectors under the Fifth Amendment and violated the Religion Clauses of the First Amendment. They asked for declaratory, injunctive, and mandamus relief and sought a three‑judge district court.
Reasoning
The District Court consolidated the cases and dismissed, citing a statutory provision, 38 U.S.C. §211(a), as barring the court’s jurisdiction and also calling the constitutional claims insubstantial. The Court of Appeals affirmed on the jurisdictional ground. The Supreme Court granted review and, in light of its decision in Johnson v. Robison, held that §211(a) does not prevent courts from considering constitutional challenges to veterans’ benefits laws. The Supreme Court therefore vacated the Court of Appeals’ judgment and remanded the case for further proceedings consistent with Johnson. The Court did not resolve the underlying constitutional claims here.
Real world impact
The decision opens the door for these conscientious objectors and others in similar situations to pursue their constitutional claims in the lower courts. The denial of benefits remains subject to further judicial review, and the case will proceed on the merits below.
Dissents or concurrances
Justice Douglas joined the result and wrote a concurrence, referring to his reasons in his separate opinion in Johnson v. Robison.
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