Henderson v. Shinseki
562 U.S. (2011)
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Rule of Law:
A statutory filing deadline for judicial review of an administrative agency decision is a non-jurisdictional claim-processing rule unless Congress provides a clear statement that it intended the deadline to be jurisdictional. The unique, pro-claimant nature of the veterans' benefits system is strong evidence against such a congressional intent.
Facts:
- David Henderson, a Korean War veteran, received a 100 percent disability rating for paranoid schizophrenia from the Department of Veterans Affairs (VA) in 1992.
- In 2001, Henderson filed a claim for supplemental benefits to cover his need for in-home care.
- A VA regional office denied Henderson's claim for supplemental benefits.
- Henderson appealed the denial to the Board of Veterans' Appeals, which made a final decision to deny his claim.
Procedural Posture:
- The Board of Veterans' Appeals issued a final decision denying David Henderson's claim for supplemental benefits.
- Henderson filed a notice of appeal in the U.S. Court of Appeals for Veterans Claims (an Article I tribunal) 15 days after the 120-day statutory deadline.
- The Veterans Court, concluding that the Supreme Court's decision in Bowles v. Russell compelled jurisdictional treatment of the deadline, dismissed Henderson's appeal for lack of jurisdiction.
- Henderson (appellant) appealed the dismissal to the U.S. Court of Appeals for the Federal Circuit.
- A divided en banc Federal Circuit affirmed the Veterans Court's judgment, holding the deadline was jurisdictional.
- The U.S. Supreme Court granted Henderson's petition for a writ of certiorari.
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Issue:
Does the 120-day statutory deadline for a veteran to file a notice of appeal with the Court of Appeals for Veterans Claims, as set forth in 38 U.S.C. § 7266(a), constitute a jurisdictional rule that bars late filings under all circumstances?
Opinions:
Majority - Justice Alito
No. The 120-day deadline to appeal to the Veterans Court is a non-jurisdictional, mandatory claim-processing rule, not a jurisdictional bar. The Court reasoned that jurisdictional labels have drastic consequences and should only be applied when Congress provides a clear statement of that intent. Here, several factors indicated no such intent: the statute's text lacks jurisdictional language; the provision is located in a subchapter titled 'Procedure,' not 'Organization and Jurisdiction'; and most importantly, the entire veterans' benefits scheme is uniquely informal, non-adversarial, and solicitous of the claimant. This pro-veteran context, which contrasts sharply with ordinary adversarial litigation, makes a rigid, unforgiving jurisdictional rule inconsistent with the system's character and the canon of construing veterans' benefits provisions in their favor.
Analysis:
This decision solidifies the Court's recent jurisprudence distinguishing between jurisdictional rules and mandatory claim-processing rules, establishing a strong presumption against jurisdictional treatment for statutory filing deadlines. It emphasizes that context, particularly the nature of the underlying administrative scheme, is critical in determining congressional intent. By refusing to extend the logic of Bowles v. Russell to the unique, pro-claimant veterans' system, the Court preserves the availability of equitable doctrines like tolling in specialized areas of law. This ruling provides courts with a clearer framework and protects litigants in claimant-friendly systems from the harsh, inflexible consequences of a jurisdictional bar.
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