Soto v. United States (VA Benefits)

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Soto v. United States

 The Barring Act, 31 U. S. C. §3702, establishes default settlement procedures for claims against the Government and subjects most claims to a 6-year limitations period. However, the Act includes an exception: If “another law” confers authority to settle a claim against the Government, that law displaces the Barring Act’s settlement mechanism, including its limitations period. §3702(a). In 2002, Congress enacted a statute providing “combat-related special compensation” (CRSC) to qualifying veterans who have suffered combat-related disabilities. 10 U. S. C. §1413a. Under federal law, retired veterans generally must waive a portion of their military retirement pay to receive Veterans Affairs (VA) disability benefits, but the CRSC statute allows combatdisabled retirees to receive special compensation up to the amount of waived retired pay. Petitioner Simon Soto served in the Marine Corps from 2000 to 2006, including two tours in Operation Iraqi Freedom. He was medically retired in 2006 and later received a 100-percent disability rating for post-traumatic stress disorder from the VA. In 2016, Soto applied for CRSC payments. The Secretary of the Navy approved his application but limited retroactive compensation to six years, citing the Barring Act’s limitations period. Soto filed a class-action lawsuit arguing that the Barring Act’s 6-year limitations period does not apply to CRSC claims because the CRSC statute constitutes “another law” that provides its own settlement mechanism. The District Court granted summary judgment for the class, but the Federal Circuit reversed, holding that the CRSC statute does not explicitly grant settlement authority and therefore cannot displace the Barring Act. 

Held: The CRSC statute confers authority to settle CRSC claims and thus displaces the Barring Act’s settlement procedures and limitations period. 

Read by Jeff Barnum.