Arellano v. McDonough

Adolfo Arellano, a Navy veteran honorably discharged in 1981, applied for VA disability benefits in 2011, claiming PTSD from a traumatic 1980 shipboard fire. The VA denied his claim as untimely because 38 U.S.C. § 5110(b)(1) requires filing within one year of discharge to receive retroactive benefits from the day after discharge. Arellano argued that his delayed-onset mental illness entitled him to equitable tolling of that deadline. The Board, Veterans Court, and Federal Circuit all ruled against him. The U.S. Supreme Court granted certiorari to resolve whether the one-year effective-date provision is subject to equitable tolling. In a unanimous opinion by Justice Amy Coney Barrett, the Court affirmed on January 23, 2023, holding that the provision is not a statute of limitations but a condition defining the effective date of an award, and therefore not subject to a presumption of equitable tolling.

The Supreme Court ruled 9-0 that the one-year effective-date provision is not subject to equitable tolling, affirming the Federal Circuit. Justice Amy Coney Barrett wrote that the text and structure of the veterans benefits scheme show the deadline is a condition on the effective date, not a traditional limitations period.

Whether 38 U.S.C. § 5110(b)(1), which sets a one-year deadline for veterans to file disability claims to receive benefits retroactive to discharge, is subject to equitable tolling when a veteran's service-connected mental illness prevented timely filing.

The decision reinforced the strictness of VA filing deadlines, limiting retroactive benefits for veterans whose service-related conditions, especially PTSD, emerge years later. It prompted renewed calls for Congress to create exceptions for delayed-onset mental health conditions and highlighted systemic barriers in veterans disability claims.