Robert M. Sellers v. Denis R. McDonough, Secretary of Veterans Affairs

When a veteran initiates a claim for disability benefits, the Department of Veterans Affairs must determine whether the veteran’s impairment is causally connected to a disease or injury suffered during military service. When a veteran is ultimately awarded disability benefits, the award’s effective date depends on when the veteran initiated the claim. This case concerns the standard for determining which disabling conditions are within the scope of a veteran’s claim. The Federal Circuit held that, even where a veteran’s disabling condition is obvious on the face of the veteran’s service records, that condition is not within the claim’s scope unless the veteran’s claim form specifically identifies that condition by name or by symptomatology. This condition-or-symptom restriction on claim scope appears nowhere in the text of the governing statutes or regulations. The only place where the rule even arguably appears is on a VA form for veterans to fill out to initiate the claims process. Ignoring this Court’s repeated admonitions about the primacy of statutory text, the Federal Circuit gave legal effect to those instructions. In so doing, it allowed the language on an agency form to override a statute conferring benefits on a disabled veteran. The question presented is: When a veteran has submitted an application for disability benefits, does the veteran’s claim encompass all reasonably identifiable conditions within the veteran’s service records?