Key Takeaways
- On June 12, 2025, the Supreme Court unanimously ruled in favor of combat veterans in Soto v. United States, holding that the Combat-Related Special Compensation statute (CRSC) supersedes the six-year statute of limitations of the Barring Act.
- Justice Clarence Thomas emphasized that a statute need not use “magic” words to bring it out of the ambit of the Barring Act. The CRSC statute necessarily includes settlement authority because it prescribes who should determine the validity of a claim and the amount due.
- Approximately 9000 veterans who were previously limited by the six-year statute now stand to benefit from the Supreme Court's ruling, receiving the full compensation they deserve.
- The decision establishes clear precedent that specific statutes addressing veterans’ benefits supersede general ones. It will influence lower courts' interpretations, potentially lengthening statutes of limitations for other causes of action.
- Reflecting the Court’s flexible view on legislative intent, the decision underscores the practice of examining the entire statutory scheme to determine Congressional intent, which may impact future cases involving statutory interpretation.
On June 12, 2025, the Supreme Court unanimously ruled in favor of combat veterans in Soto v. United States. The question presented to the Court was whether the Combat-Related Special Compensation statute (“CRSC”) provided a settlement mechanism (i.e., a mechanism for determining the validity of a veteran’s claim) that supersedes the six-year statute of limitations enshrined in the Barring Act (31 U.S.C. § 3702). The case has significant implications not only for the 9000 veterans in the proposed class benefiting from this ruling, but on jurisprudence and interpretations of Congressional intent more broadly.
Background of the Case
Simon A. Soto is a retired U.S. Marine Corp veteran with a combat-related disability of at least 10%. Mr. Soto was first eligible for benefits in 2009, but did not apply for CSRC until 2016. The Department of the Navy initially approved his claim, but limited retroactive payments to six years prior to his application, citing the Barring Act’s six-year statute of limitations. Soto argued that the CRSC should be interpreted as a specific statute that displaces the Barring Act’s limitations. The Southern District of Texas initially agreed in 2021, relying in part on the pro-veteran canon as set forth in Brown v. Gardner, 513 U.S. 115 (1994) to grant summary judgment in favor of Mr. Soto and his proposed class. The Federal Circuit, however, reversed, holding that the CRSC statute cannot displace the Barring Act without a specific provision setting out the period of recovery.
The Supreme Court’s Decision
The Supreme Court reversed the Federal Circuit, finding that a statute need not use “magic” words like “settle” to bring it out of the ambit of the Barring Act. Rather, because the CRSC prescribes both who should determine the validity of a claim and the amount due, the CRSC necessarily confers settlement authority. In the unanimous decision by the Supreme Court, Justice Clarence Thomas noted “[w]here, as here, the statutory scheme involves a small group of particularly deserving claimants, it is not extraordinary to think that Congress wished to forgo a limitations period.”
The ruling applies not just to Mr. Soto, but to the approximately 9000 veterans receiving combat-related special compensation whose compensation was limited by the prior six-year time limit. Similarly situated veterans can contact legal services programs such as NVLSP for further information. NVLSP, the National Veterans Legal Services Program, helped bring the suit that resulted in the Supreme Court’s decision. In a public statement, NVLSP’s Executive Director Paul Wright noted that the decision ensures that these veterans “will finally receive the full amount of the compensation they earned through their service and sacrifice.”
Impacts on VA and Federal Jurisprudence
One major acute consequence of this opinion will be the influx of 9000 or so new claims to VA and each military department, as this decision will resurrect many older claims from veterans who were previously barred by the six year statute of limitations. VA is already facing the prospect of widespread layoffs, with the Office of Personnel Management recently announcing a goal of cutting more than 80,000 positions in the next year. In addition to the strain on Regional Offices, the Court of Appeals for Veterans Claims and the Federal Circuit will likely see an uptick in veterans appeals from CRSC denials or rating decisions in the common years. And in combination with a potential view of Soto as conferring greater agency settlement discretion, this uptick in appeals may lead to greater deference to agency determinations of claim validity and fewer reversals or remands.
The Supreme Court’s common-sense approach to determining whether a specific statute supersedes a general one will also have a ripple effect on the Federal Circuit and lower courts. The Court provides guidance on how to interpret statutes that potentially conflict with general laws governing procedure, like the Barring Act, and Mr. Soto’s victory establishes clear precedent that specific statutes addressing veterans’ benefits supersede general ones. Lower courts will be bound by this precedent in interpreting statutes not just in the veterans context but for tort and contract claims, potentially lengthening statutes of limitations for other causes of action. The case will also bring veterans’ appeals back into line with Brown v. Gardner and the pro-veteran canon, potentially leading to more favorable statutory interpretation and favorable outcomes for veterans seeking benefits.
Additionally, and importantly, this case reflects the current Court’s expansive and flexible view of legislative intent. Following cases like Department of Agriculture Rural Development Rural Housing Service v. Kirtz, 601 U.S. 42 (2024) and Winkelman v. Parma City School District, 550 U.S. 516 (2007), the Court notes that “Congress need not ‘state its intent in any particular way,’” demonstrating its willingness to “look to the text, context, and structure of ‘the entire statutory scheme’ at issue” to decide issues of legislative intent. This case may reverberate in the future as the Supreme Court grapples with interpretive issues over the next year, including free speech (Free Speech Coalition v. Paxton), sentence reductions for non-retroactive changes to criminal law (Rutherford v. United States), and timing for setting aside default judgments where personal jurisdiction is defective (Coney Island Auto Parts v. Burton). Time will tell if the Court’s congressional intent jurisprudence continues to expand.
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