Arellano v. McDonough

Navy veteran Adolfo R. Arellano applied for disability benefits nearly 30 years after his discharge, attributing the delay to service-connected psychiatric disorders. The Department of Veterans Affairs (VA) granted the benefits but assigned the effective date as the date of his application, not his discharge. Arellano appealed, arguing that the statutory one-year filing deadline for retroactive benefits should be equitably tolled due to his mental incapacity. The U.S. Supreme Court, in a unanimous decision authored by Justice Amy Coney Barrett, held that Section 5110(b)(1) of Title 38 is not subject to equitable tolling, emphasizing that Congress did not intend for the strictly defined effective date rules to admit exceptions. The ruling affirmed the Federal Circuit’s decision.

The U.S. Supreme Court unanimously ruled that the statute 38 U.S.C. § 5110(b)(1) is a mandatory and absolute deadline that cannot be equitably tolled. The veteran could not receive disability benefits retroactive to the date of his discharge.

Whether the one-year statutory deadline for a veteran to apply for disability benefits to receive a retroactive effective date back to discharge can be extended under the doctrine of equitable tolling due to mental illness.

The decision set a strict boundary on veterans' claims for retroactive benefits, affirming that Congress alone has the authority to create exceptions to statutory filing deadlines. It closed the door on a potential pathway for veterans with long-delayed mental health diagnoses to recover benefits spanning decades, prompting advocacy groups to call for legislative reform to address the gap.