Arellano v. McDonough

Background

Adolfo Arellano, a Navy veteran discharged in 1981, applied for disability compensation about 30 years later. A VA regional office found his psychiatric disorders were service-related and set the effective date as June 3, 2011, the day the VA received his claim. Arellano asked the VA to treat his award as effective the day after his discharge under a statutory exception that applies if an application is received within one year of discharge. He argued the one-year window should be equitably tolled because illness prevented earlier filing. The VA and lower courts denied relief, and the Supreme Court took the case to resolve the legal question.

Reasoning

The Court addressed whether the one-year exception in 38 U.S.C. §5110(b)(1) can be extended by equitable tolling, a fairness-based doctrine that pauses time limits in exceptional cases. The majority explained that the statute sets a default rule—effective dates start at claim receipt—“unless specifically provided otherwise” and lists 16 specific exceptions. That detailed scheme, including other provisions that already account for disability-caused delay and generally cap retroactive awards, shows Congress chose narrow, specific rules rather than open-ended equitable exceptions. Because the statutory text and structure rebut the presumption favoring equitable tolling, the Court held §5110(b)(1) is not subject to equitable tolling.

Real world impact

The decision means agencies and courts may not extend §5110(b)(1)’s one-year effective-date window on equitable grounds. Veterans cannot use equitable tolling to turn very late claims into decades-long retroactive awards under that provision. The Court limited its holding to equitable tolling and did not decide other equitable doctrines.