The Supreme Court ruled March 5, 2025, in *Bufkin v. Collins*, a case that clarifies how the Department of Veterans Affairs must apply its "benefit-of-the-doubt" rule when processing veterans' claims for post-traumatic stress disorder disability benefits.
The case involved two veterans, Joshua Bufkin and Norman Thornton, who challenged adverse VA determinations regarding their PTSD claims. Under federal law, the VA applies a "benefit-of-the-doubt rule" codified in 38 U.S.C. § 5107(b) that requires the agency to tip the scales in a veteran's favor when evidence regarding any issue material to a service-related disability claim is in "approximate balance."
Bufkin claimed his PTSD stemmed from his military service, but the VA found no clear link between his condition and his service. The agency denied his claim for service-connected PTSD disability benefits. Thornton had previously obtained service-connected PTSD disability benefits but was seeking an increased disability rating. The VA denied his most recent request for a higher rating.
Both veterans' cases followed the standard VA appeals process. The Board of Veterans' Appeals reviewed the adverse determinations de novo and rendered final decisions on behalf of the VA denying both claims. The veterans then challenged these determinations before the U.S. Court of Appeals for Veterans Claims, known as the Veterans Court.
Under 38 U.S.C. § 7261(a), the Veterans Court reviews legal issues de novo and factual issues for clear error. Additionally, under § 7261(b)(1), the Veterans Court must "take due account" of the VA's application of the benefit-of-the-doubt rule when reviewing cases. Applying these standards, the Veterans Court affirmed the VA's adverse benefit determinations in both cases.
The veterans then appealed to the Federal Circuit Court of Appeals, which has jurisdiction over veterans' benefits cases. The case eventually reached the Supreme Court, which granted certiorari and heard oral arguments on October 16, 2024.
The benefit-of-the-doubt rule represents a pro-veteran standard designed to resolve evidentiary disputes in favor of claimants when the evidence is roughly equal on both sides. This rule reflects Congress's intent to create a veteran-friendly adjudication system that recognizes the unique challenges veterans face in documenting service-connected disabilities, particularly mental health conditions like PTSD.
PTSD cases present particular challenges for the VA's adjudication process. Unlike physical injuries with clear medical documentation, PTSD often develops over time and may not manifest symptoms until years after military service. Veterans seeking PTSD benefits must typically establish both that they have the condition and that it relates to their military service, which can involve complex factual determinations about traumatic events that occurred during service.
The case comes at a time when the VA processes hundreds of thousands of disability claims annually, with PTSD representing one of the most common conditions claimed by veterans. According to VA data, PTSD affects significant numbers of veterans who served in Iraq and Afghanistan, as well as veterans from earlier conflicts.
The Supreme Court's decision in *Bufkin* will likely provide important guidance to the VA, the Veterans Court, and the Federal Circuit regarding how courts should review the agency's application of the benefit-of-the-doubt rule. The ruling may clarify the relationship between the Veterans Court's clear error standard for factual review and its obligation to take "due account" of the VA's benefit-of-the-doubt determinations.
Veterans' advocacy organizations have long argued that the VA should apply the benefit-of-the-doubt rule more liberally, particularly in cases involving PTSD and other mental health conditions where evidence may be inherently difficult to obtain or present. They contend that the rule's purpose is to ensure veterans receive the benefit of reasonable doubt when evidence is inconclusive.
The VA, meanwhile, must balance its obligation to provide benefits to deserving veterans with its responsibility to ensure claims are supported by adequate evidence. The agency processes over one million disability claims annually and must maintain consistent standards across its regional offices nationwide.
The decision in *Bufkin* follows other recent Supreme Court cases addressing veterans' benefits, reflecting the high court's ongoing attention to issues affecting military veterans. These cases often involve questions about the scope of judicial review over VA determinations and the proper application of veteran-friendly adjudication standards.
The Federal Circuit, which heard the case before it reached the Supreme Court, has exclusive jurisdiction over appeals from the Veterans Court. This specialized appellate structure was designed to create consistency in veterans' benefits law, but it also means that Supreme Court review represents the final opportunity to resolve disputes about the proper interpretation of veterans' benefits statutes.
The March 5, 2025, decision date indicates the Court took several months to deliberate after oral arguments, suggesting the justices grappled with complex questions about the interaction between different standards of review and the proper application of pro-veteran adjudication rules. The full implications of the Court's ruling will likely become clearer as lower courts and the VA apply the decision to future cases involving the benefit-of-the-doubt rule and PTSD claims.