Bufkin v. Collins

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Supreme Court of the United States
Bufkin v. Collins
Term: 2024
Important Dates
Argued: October 16, 2024
Decided: March 2, 2025
Outcome
Affirmed
Vote
7-2
Majority
Chief Justice John Roberts • Clarence Thomas • Samuel Alito • Sonia Sotomayor • Elena Kagan • Brett Kavanaugh • Amy Coney Barrett •
Dissenting
Ketanji Brown Jackson • Neil Gorsuch
This article is about the court case previously known as Bufkin v. McDonough; it became Bufkin v. Collins when Doug Collins became the U.S. Secretary of Veterans Affairs.

Bufkin v. Collins is a case that was decided by the Supreme Court of the United States on March 5, 2025, during the court's October 2024-2025 term. The case was argued before the Supreme Court of the United States on October 16, 2024.

In a 7-2 opinion, the court held that the Department of Veterans Affairs’ determination that the evidence regarding a service-related disability claim is in “approximate balance” pursuant to the “benefit-of-the-doubt rule” is a predominantly factual determination reviewed only for clear error. Justice Clarence Thomas delivered the opinion of the court.[1] Click here for more information about the ruling.

HIGHLIGHTS
  • The issue: The case concerned enforcement of the benefit-of-the-doubt rule under Title 38 of the United States Code on military veterans' benefits claims. The rule means that in veterans' law cases, the veteran, rather than the government, receives the benefit of the doubt in their claims. Click here to learn more about the case's background.
  • The questions presented: "Must the Veterans Court ensure that the benefit-of-the-doubt rule was properly applied during the claims process in order to satisfy 38 U.S.C. § 7261(b)(1), which directs the Veterans Court to 'take due account' of VA's application of that rule?"[2]
  • The outcome: In a 7-2 opinion, the court affirmed the decision of the United States Court of Appeals for the Federal Circuit.[1]


    • The case came on a writ of certiorari to the United States Court of Appeals for the Federal Circuit. To review the lower court's opinion, click here.

    Background

    Case summary

    The following are the parties to this case:[3]

    The following summary of the case was published by Oyez, a free law project from Cornell’s Legal Information Institute

    “

    Veterans Joshua Bufkin and Norman Thornton were each denied benefits despite evidence that appeared to be in “approximate balance.” The benefit-of-the-doubt rule, codified at 38 U.S.C. § 5107(b), provides that, “[w]hen there is an approximate balance of positive and negative evidence regarding any issue material to the determination of a matter, the Secretary [of Veterans Affairs] shall give the benefit of the doubt to the claimant.” However, in reviewing the Veterans Court decision, the U.S. Court of Appeals for the Federal Circuit held that Section 7261(b)(1), which requires the U.S. Court of Appeals for Veterans Claims to “take due account of the Department of Veterans Affairs’ application of that rule “does not require the Veterans Court to conduct any review of the benefit of the doubt issue beyond” performing the usual review of the underlying factual findings for clear error—a basic procedural requirement that was already in place before enactment of the Veterans Benefits Act.[5]

    		”

    To learn more about this case, see the following:

    Timeline

    The following timeline details key events in this case:

    Questions presented

    The petitioner presented the following questions to the court:[2]

    Questions presented:
    “ Must the Veterans Court ensure that the benefit-of-the-doubt rule was properly applied during the claims process in order to satisfy 38 U.S.C. § 7261(b)(1), which directs the Veterans Court to 'take due account' of VA's application of that rule?[5] ”

    Oral argument

    The U.S. Supreme Court heard oral argument on October 16, 2024.

    Audio

    Audio of oral argument:[7]



    Transcript

    Transcript of oral argument:[8]

    Outcome

    In a 7-2 opinion, the court held that the Department of Veterans Affairs’ determination that the evidence regarding a service-related disability claim is in “approximate balance” pursuant to the “benefit-of-the-doubt rule” is a predominantly factual determination reviewed only for clear error. Justice Clarence Thomas delivered the opinion of the court.[1]

    Opinion

    In the opinion of the Court, Justice Thomas wrote:[1]

    “ Section 7261(b)(1) does not establish a new standard of review for challenges to the VA’s application of the benefit-of-the-doubt rule. Instead, it requires the Veterans Court to apply the appropriate standard of review under §7261(a). Because the VA’s approximate-balance determination is a predominantly factual question, the Veterans Court reviews it for clear error. §7261(a)(4)... The judgment of the Court of Appeals is affirmed.[5] ”

    Dissenting opinion

    In a dissenting opinion, Justice Ketanji Brown Jackson wrote, joined by Neil Gorsuch:[1]

    “ In short, the Court today concludes that Congress meant nothing when it inserted subsection (b)(1) in response to concerns that the Veterans Court was improperly rubberstamping the VA’s benefit-of-the-doubt determinations, and also that the Veterans Court is not obliged to do anything more than defer to those agency decisions notwithstanding Congress’s “take due account” direction. I respectfully dissent.[5] ”

    Text of the opinion

    Read the full opinion here.

    October term 2024-2025

    See also: Supreme Court cases, October term 2024-2025

    The Supreme Court began hearing cases for the term on October 7, 2024. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[9]


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 1.4 Bufkin v. Collins, decided March 5, 2025
    2. ↑ 2.0 2.1 U.S. Supreme Court, "23-713 BUFKIN V. McDONOUGH," accessed April 30, 2024
    3. ↑ Supreme Court of the United States, "No. 23-713," accessed August 6, 2024
    4. ↑ Note: At the time of argument, legal counsel was given by former United States Solicitor General Elizabeth Prelogar.
    5. ↑ 5.0 5.1 5.2 5.3 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    6. ↑ U.S. Court of Appeals for the Federal Circuit, Bufkin v. McDonough, decided August 3, 2023
    7. ↑ Supreme Court of the United States, "Oral Argument - Audio," argued October 16, 2024
    8. ↑ Supreme Court of the United States, "Oral Argument - Transcript," argued October 16, 2024
    9. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed January 24, 2022
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