Traynor v. Turnage
Headline: Court allows lawsuits and upholds VA rule treating primary alcoholism as willful misconduct, making some recovered veterans ineligible for extended educational benefits.
Holding: The Court held that federal courts can review VA rules under the Rehabilitation Act and that the VA regulation treating primary alcoholism as willful misconduct does not violate that Act, so the regulation stands.
- Allows courts to hear VA rule challenges under the Rehabilitation Act.
- Affirms VA policy can deny extensions to veterans with primary alcoholism.
- Veterans must present individualized medical evidence on appeal.
Summary
Background
Two honorably discharged veterans, Eugene Traynor and James McKelvey, asked the Veterans’ Administration (VA) for extra time to use their education benefits because alcoholism had kept them from using benefits within the usual 10-year limit. The VA denied their requests under a regulation that treats “primary” alcoholism (not caused by an underlying psychiatric disorder) as the veteran’s own willful misconduct. Lower courts split on whether those denials could be reviewed by judges and whether the VA rule violated the Rehabilitation Act’s ban on discrimination against people with disabilities.
Reasoning
The Court first held that the general statutory bar against reviewing VA benefit decisions (§211(a)) does not prevent federal courts from hearing claims that a VA rule conflicts with the Rehabilitation Act. The Court then examined the merits and concluded that Congress, when it amended the education benefit law in 1977 and referenced the VA’s existing standard, intended the term “willful misconduct” to be applied as the VA had long interpreted it. The Court found no clear conflict between that specific rule and the later Rehabilitation Act amendments and therefore held that the VA regulation does not violate §504.
Real world impact
As a practical result, courts may hear challenges to VA regulations under the Rehabilitation Act, but the VA may continue to apply its regulation that treats primary alcoholism as willful misconduct for the purpose of denying extensions. The Court affirmed the D.C. Circuit’s judgment and reversed the Second Circuit, remanding for further proceedings consistent with the opinion.
Dissents or concurrances
Justice Blackmun (joined by Justices Brennan and Marshall) agreed on reviewability but dissented on the merits, arguing the VA’s irrebuttable presumption violates the Rehabilitation Act and that individualized medical determinations are required.
Opinions in this case:
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