The U.S. Supreme Court has ruled in Bufkin v. Collins that federal appellate courts are not required to independently reassess how the Department of Veterans Affairs (VA) applies the “benefit-of-the-doubt” rule when reviewing disability claims. The decision, a 7-2 majority, clarifies the scope of judicial review for veterans’ appeals.
The benefit-of-the-doubt rule is central to VA claims: when evidence for and against a claim is evenly balanced, any uncertainty should favor the veteran. It exists to help veterans who may lack complete medical documentation from their service.
The case focused on two veterans—Joshua Bufkin (Air Force) and Norman Thornton (Army, Gulf War)—both seeking PTSD-related benefits amid conflicting medical assessments. Their claims had been denied, and lower courts upheld these decisions without re-evaluating the benefit-of-the-doubt standard.
Justice Clarence Thomas, writing for the majority, emphasized that appellate courts should defer to the VA’s expertise in medical and factual determinations unless a clear error is present. Legal issues receive independent review, but factual findings—including the application of the benefit-of-the-doubt—are reviewed more narrowly. The ruling reinforces that specialized agencies like the VA are trusted to make reasonable, evidence-supported decisions.
Implications for veterans: Appeals will now face a higher threshold. Evenly balanced evidence alone is insufficient; veterans must show significant errors in the VA’s evaluation. While this may reduce successful appeals in borderline cases, it also clarifies the review process and underscores the importance of thorough, well-documented claims from the start.
This ruling marks a significant shift in veterans’ disability law, emphasizing agency discretion and the need for strong, early documentation.
