Supreme Court Report

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Mark H. Bonner v. Denis R. McDonough, Secretary of Veterans Affairs

Paid petition · United States Court of Appeals for the Federal Circuit, No. 21-1817 · judgment December 14, 2021


Certiorari denied · October 3, 2022
Pre-decision estimate: 0% cert probability

Before the decision, well below the 4.1% base rate, with no standout signals pointing toward a grant.

Question presented

The U.S. Court of Appeals for Veterans Claims is an Article I court, and does not have the general equity jurisdiction of U.S. District Courts or other Article III courts. Where it does exercise equitable powers, it is pursuant to specific statutory grant. Veterans claims alleging Clear and Unmistakable Error (CUE) are, by statute, exceptions to the doctrine of res judicata (claim preclusion). The questions presented are:

  1. Whether it is within the jurisdiction of the U.S. Court of Appeals for Veterans Claims to decide a veteran’s claim on the basis of the equitable remedy of collateral estoppel where no statute so provides.

  2. Whether it is within the jurisdiction of the U.S. Court of Appeals for Veterans Claims to deny a CUE claim on the basis of Collateral Estoppel (issue preclusion) where it is forbidden to do so on the basis of Res Judicata (claim preclusion).

Counsel of record

For petitioner
Mark Healy Bonner

For respondent
Elizabeth B. Prelogar
Solicitor General

Case

Conference history
Distributed for 1 conference

Proceedings

  1. Oct 03 2022
    Petition DENIED.
  2. Jun 22 2022
    DISTRIBUTED for Conference of 9/28/2022.
  3. Jun 16 2022
    Waiver of right of respondent McDonough, Secretary of Veterans Affairs,, Denis to respond filed.
  4. May 26 2022
    Petition for a writ of certiorari filed. (Response due July 1, 2022)