Arellano v. McDonough

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Arellano v. McDonough is a landmark decision by the Supreme Court of the United States that addressed the issue of whether the one-year deadline for filing a claim for retroactive disability benefits with the Department of Veterans Affairs (VA) is subject to equitable tolling. The case was decided on January 23, 2023, with the Court ruling unanimously that the deadline is not subject to equitable tolling.

Background

The case arose from a claim filed by veteran Alfred Arellano, who sought retroactive disability benefits from the VA. Arellano argued that his mental health condition, which was service-connected, prevented him from filing his claim within the one-year deadline. He contended that the deadline should be equitably tolled due to his condition.

The United States Court of Appeals for Veterans Claims initially heard the case and ruled against Arellano, stating that the statutory deadline was not subject to equitable tolling. Arellano then appealed to the Supreme Court.

Legal Issues

The primary legal issue in Arellano v. McDonough was whether the statutory one-year deadline for filing a claim for retroactive disability benefits under 38 U.S.C. § 5110(b)(1) could be equitably tolled. Equitable tolling is a doctrine that allows courts to extend a statute of limitations in cases where a plaintiff, through no fault of their own, was unable to file a claim within the prescribed time period.

Supreme Court Decision

The Supreme Court, in a unanimous opinion authored by Justice Amy Coney Barrett, held that the one-year deadline for filing a claim for retroactive disability benefits is not subject to equitable tolling. The Court reasoned that Congress had established a clear and unambiguous deadline in the statute, and there was no indication that Congress intended for equitable tolling to apply.

Justice Barrett's opinion emphasized the importance of adhering to statutory text and the role of Congress in setting deadlines for claims. The decision underscored the principle that courts should not extend statutory deadlines unless explicitly authorized by Congress.

Impact

The decision in Arellano v. McDonough has significant implications for veterans seeking retroactive disability benefits. It reinforces the strict adherence to statutory deadlines and limits the ability of courts to apply equitable tolling in cases involving claims against the VA.

Also see

• Department of Veterans Affairs
• Equitable tolling
• Statute of limitations
• Supreme Court of the United States