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Keywords

appealregulation

motionregulation

Related Cases

Kisor v. Wilkie

Facts

James Kisor, a Vietnam War veteran, sought disability benefits from the Department of Veterans Affairs (VA) for post-traumatic stress disorder (PTSD) stemming from his military service. Initially denied benefits in 1982, Kisor reopened his claim in 2006, and the VA acknowledged his PTSD but only granted benefits from the date of his reopening. The Board of Veterans`Appeals upheld the VA's decision, interpreting the relevant regulation to deny retroactive benefits based on the agency's view of what constituted 'relevant' records.

Kisor is a Vietnam War veteran seeking disability benefits from the Department of Veterans Affairs (VA). He first applied in 1982, alleging that he had developed post-traumatic stress disorder (PTSD) as a result of his participation in a military action called Operation Harvest Moon. The report of the agencys evaluating psychiatrist noted Kisors involvement in that battle, but found that he �[id] not suffer from PTSD.�App. 12, 14. The VA thus denied Kisor benefits. There matters stood until 2006, when Kisor moved to reopen his claim. Based on a new psychiatric report, the VA this time agreed that Kisor suffered from PTSD. But it granted him benefits only from the date of his motion to reopen, rather than (as he requested) from the date of his first application.

Issue

Whether the Supreme Court should overrule the Auer deference doctrine, which allows courts to defer to agencies' interpretations of their own ambiguous regulations.

The only question presented here is whether we should overrule those decisions, discarding the deference they give to agencies. We answer that question no.

Rule

Auer deference applies when a regulation is genuinely ambiguous, allowing courts to defer to an agency's reasonable interpretation of its own regulations unless that interpretation is plainly erroneous or inconsistent with the regulation.

Auer deference is sometimes appropriate and sometimes not. Whether to apply it depends on a range of considerations that we have noted now and again, but compile and further develop today.

Analysis

The Court determined that Auer deference retains an important role in construing agency regulations, but it also reinforced the limits of this deference. The Court emphasized that a court must first ascertain whether a regulation is genuinely ambiguous before applying Auer deference. In this case, the lower court did not make a sufficient effort to determine the ambiguity of the VA regulation, leading to an improper application of Auer deference.

But even as we uphold it, we reinforce its limits. Auer deference is sometimes appropriate and sometimes not. Whether to apply it depends on a range of considerations that we have noted now and again, but compile and further develop today.

Conclusion

The Supreme Court vacated the judgment of the lower court and remanded the case for further proceedings, emphasizing the need for a proper assessment of the regulation's ambiguity before applying Auer deference.

The judgment was vacated and remanded where the lower court had not made a conscientious effort to determine whether the VA regulation at issue was ambiguous and had improperly assumed that Auer deference applied if the regulation was genuinely ambiguous.

Who won?

The prevailing party was Kisor, as the Supreme Court's decision vacated the lower court's judgment and remanded the case for further consideration of the VA regulation's ambiguity.

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