Reynolds v. United States

Background

A Spanish-American War veteran who had been honorably discharged suffered a neuropsychiatric illness and was committed in 1911 to St. Elizabeths Hospital by the Secretary of the Interior under statutory authority. He remained confined as an insane person until his discharge in 1930. While he was in the hospital, pension money was credited to him, and the Government later applied that pension to pay his board. The veteran sued to recover the pension money; the lower court ruled for the United States. The Supreme Court granted review and reversed the lower court on May 28, 1934.

Reasoning

The central question was whether the Government could withhold pension payments credited while the veteran was confined and use them to pay hospital board. The Court explained that when the Veterans Bureau had the right to use a hospital, that hospital’s facilities were under the Bureau’s control within the meaning of §202(10) of the World War Veterans Act, as amended in 1926. The Court held that the statute’s proviso prohibited withholding pension money credited during confinement to pay for the veteran’s board, and that rule applied to charges incurred before July 2, 1926 as well as afterwards when the deduction was made after the proviso became effective. The Court also noted that a statute is not made retroactive merely because it relies on facts from before the law’s enactment. Justice Sutherland delivered the opinion.

Real world impact

The decision lets this veteran seek and recover pension money that the Government applied to his hospital board. It means veterans in similar situations—honorably discharged and confined where the Veterans Bureau used the facility—may challenge withheld pension credits. The ruling also treats board charges before and after July 2, 1926 as covered when the deduction occurred after the proviso took effect.