Bufkin诉Collins案

Veterans Joshua Bufkin and Norman Thornton sought service-connected PTSD disability benefits from the Department of Veterans Affairs (VA). Bufkin's claim was denied for insufficient evidence linking his PTSD to military service, while Thornton's request for an increased rating was denied. The Board of Veterans' Appeals upheld both denials, and the Veterans Court affirmed, finding no clear error. The Federal Circuit also affirmed. The Supreme Court granted certiorari to determine the appropriate standard of review for the VA's "approximate balance" determination under the benefit-of-the-doubt rule.

The Supreme Court affirmed the lower courts' decisions in a 7-2 vote. Justice Clarence Thomas authored the majority opinion, holding that the VA's approximate-balance determination is predominantly factual and thus reviewed only for clear error. Justices Ketanji Brown Jackson and Neil Gorsuch dissented.

Whether the VA's determination that evidence is in "approximate balance" under the benefit-of-the-doubt rule (38 U.S.C. § 5107(b)) is a factual determination subject to clear-error review or a legal determination subject to de novo review.

The decision clarified the standard of review for veterans' disability claims, affirming that deference is given to the VA's factual determinations regarding evidentiary balance. This may impact thousands of veterans' claims by making it more difficult to overturn VA denials on appeal. The ruling resolved a circuit split and provided guidance to the Veterans Court on applying the benefit-of-the-doubt rule.