Eric K. Shinseki, Secretary of Veterans Affairs v. Woodrow F. Sanders (556 U.S. 396)
U.S. Supreme Court · decided April 21, 2009 · Supreme Court Database (Spaeth)
- Citation
- 556 U.S. 396 · 129 S. Ct. 1696
- Decided
- April 21, 2009
- Term
- October Term 2008
- Vote
- 6–3
- Majority author
- Justice Breyer
- Issue area
- Civil Rights
- Disposition
- Reversed and remanded
- Outcome
- Petitioning party won
- Ideological direction
- Conservative
Opinion excerpt
Justice Breyer delivered the opinion of the Court. In these two civil cases, the Department of Veterans Affairs (VA) denied veterans’ claims for disability benefits. In both cases the VA erroneously failed to provide the veteran with a certain kind of statutorily required notice. See 38 U. S. C. § 5103(a). In both cases the VA argued that the error was harmless. And in both cases the Court of Appeals for the Federal Circuit, after setting forth a framework for determining whether a notice error is harmless, rejected the VA’s argument. In our view, the Federal Circuit’s “harmless-error” framework is too complex and rigid, its presumptions impose unreasonable evidentiary burdens upon the VA, and it is too likely too often to require the Court of Appeals for Veterans Claims (Veterans Court) to treat as harmful errors that in fact are harmless. We conclude that the framework conflicts with established law. See § 7261(b)(2) (Veterans Court must “take due account of the rule of prejudicial error”). I A The law entitles veterans who have served on active duty in the United States military to receive benefits for disabilities caused or aggravated by their military service. The Veterans Claims Assistance Act of 2000 requires the VA to help a veteran develop his or her benefits claim. §5103A. In doing so, the Secretary of Veterans Affairs (Secretary), upon “receipt of” an “application”…
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