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Keywords

appealmotionregulationrelevance

Related Cases

Kisor v. Wilkie, 588 U.S. 558, 139 S.Ct. 2400, 204 L.Ed.2d 841, Fed. Sec. L. Rep. P 100,511, Med & Med GD (CCH) P 306,540, 19 Cal. Daily Op. Serv. 6045, 2019 Daily Journal D.A.R. 5784, 27 Fla. L. Weekly Fed. S 1091

Facts

James Kisor, a Vietnam War veteran, first applied for disability benefits from the Department of Veterans Affairs (VA) in 1982, claiming he developed post-traumatic stress disorder (PTSD) due to his military service. His initial claim was denied, but in 2006, he sought to reopen the claim, which the VA granted, providing benefits only from the date of his motion to reopen rather than from his original application date. The Board of Veterans’ Appeals upheld this decision, interpreting a VA regulation regarding the relevance of new service records.

Issue

Whether the Federal Circuit properly applied Auer deference to the Board's interpretation of the VA regulation regarding the effective date for disability benefits.

Rule

Auer deference allows courts to defer to an agency's reasonable interpretation of its own genuinely ambiguous regulations, but this deference is limited and should only be applied after exhausting traditional interpretive tools.

Analysis

The Supreme Court found that the Federal Circuit prematurely declared the VA regulation ambiguous without fully applying all interpretive tools. The Court emphasized that Auer deference should not be applied unless the regulation is genuinely ambiguous and that the agency's interpretation must be reasonable and authoritative. The Court also noted that the character and context of the agency's interpretation must warrant deference.

Conclusion

The Supreme Court vacated the judgment of the Federal Circuit and remanded the case for reconsideration of whether Auer deference was appropriate in Kisor's case.

Who won?

The prevailing party was the Department of Veterans Affairs, as the Supreme Court upheld the principle of Auer deference, allowing the agency's interpretation to stand pending further review.

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