Supreme Court Decision in Bufkin v. Collins Raises the Bar for Veterans Seeking Disability Benefits
In a significant and controversial decision, the U.S. Supreme Court ruled 7-2 in Bufkin v. Collins that courts must give strong deference to decisions made by the Department of Veterans Affairs (VA), unless there is a clear and unmistakable error. This landmark ruling has profound implications for how veterans’ disability claims are evaluated and challenged in the legal system.
For decades, the VA’s “benefit-of-the-doubt” rule served as a critical safeguard for veterans, ensuring that when evidence supporting and opposing a claim was in approximate balance, the decision would favor the veteran. This principle recognized the unique sacrifices made by service members and the inherent difficulties in documenting service-connected conditions, particularly mental health issues like PTSD.
However, the Court’s decision in Bufkin significantly weakens that protective standard. The justices concluded that courts must not overturn VA decisions unless they find an unmistakable error—an exceedingly high threshold that is rarely met. This ruling effectively shifts the burden onto veterans to present overwhelmingly convincing evidence to reverse a denial, even when the facts of a case are closely contested.
The case centered on two veterans, Joshua Bufkin and Norman Thornton, both of whom sought disability compensation for post-traumatic stress disorder (PTSD). Despite presenting substantial and credible evidence to support their claims, the VA denied them benefits.
Under the previous interpretation of the benefit-of-the-doubt rule, their claims might have succeeded. But under the new standard, their denials stand unless they can prove the VA made a clear and egregious error.
Veterans’ advocates have expressed concern that the decision undermines the intent of the benefit-of-the-doubt rule and erects new barriers for those already struggling to navigate a complex and often unforgiving system. Critics argue that the ruling may discourage deserving veterans from appealing VA decisions, knowing that the burden of proof is now considerably steeper.
In summary, the Supreme Court’s ruling in Bufkin v. Collins marks a pivotal shift in veterans law, redefining the balance between judicial oversight and agency deference. While intended to preserve the VA’s autonomy and expertise, the decision may come at a cost—making it more difficult for veterans to receive the benefits they have earned through service and sacrifice.
