Facts of the Case

Provided by Oyez

Simon Soto, a Marine Corps veteran with a combat-related disability, was medically retired in 2006 with less than 20 years of service. Although he became eligible for Combat-Related Special Compensation (CRSC) in 2009 when he received his disability rating, he did not apply until 2016. The Navy used the Barring Act’s six-year limitation period to calculate his retroactive payments, giving him payments dating back only to 2010 instead of to 2008 when Congress had expanded CRSC eligibility to veterans with less than 20 years of service. Soto filed a class action lawsuit on behalf of himself and other similarly situated veterans who received only six years of back payments, arguing that the CRSC statute’s own procedures should apply instead of the Barring Act’s six-year limit.

The district court granted summary judgment to Soto’s class, holding that the CRSC statute was more specific and therefore superseded the Barring Act. The court also applied the pro-veteran canon of statutory interpretation, resolving any doubt in favor of the veterans. On appeal, the U.S. Court of Appeals for the Federal Circuit reversed.

Questions

  1. When disabled combat veterans claim past-due compensation, should the military use the CRSC statute's rules to calculate how far back they can be paid, or should it use the Barring Act's six-year limit?

Conclusions

  1. The statute that provides combat-related special compensation (CRSC) to disabled veterans establishes its own settlement process for claims, which supersedes the Barring Act’s default six-year statute of limitations for most claims against the federal government. Justice Clarence Thomas authored the unanimous opinion of the Court.

    In the context of government claims, “settling” a claim means determining whether the claim is valid and, if so, computing the amount the claimant is owed. Congress does not need to use explicit wording such as the term “settle” to establish this authority; it is enough if, taken as a whole, the statute authorizes an agency to decide both whether a person is entitled to payment and how much payment is due. The CRSC statute gives the relevant military secretary the power to determine eligibility and the exact compensation owed based on statutory formulas. By establishing a comprehensive, self-contained scheme that charges the secretary with both validating claims and setting the payment amount, the statute creates a separate claim-settling process.

    Because the CRSC statute authorizes the relevant officials to determine both entitlement and the amount of CRSC payments, the law functions as “another law” with its own settlement mechanism under the Barring Act. As a result, the default 6-year limitation period of the Barring Act does not apply to CRSC claims, regardless of whether the CRSC statute contains its own explicit time restriction. This ruling clarifies that Congress can displace default government claim procedures—including limitations periods—when it provides a comprehensive statutory process for resolving specific claims, as it did for CRSC benefits.