Bufkin v. Collins
In brief
The VA generally gets the final call on whether disability-claim evidence is evenly balanced unless its factual assessment is clearly wrong.
- Where it stands
- Decided
Decided 7-2 · March 5, 2025 · Opinion by Justice Thomas
- What it’s about
- This case concerns the standard of review the U.S. Court of Appeals for Veterans Claims must use when examining whether the Department of Veterans Affairs properly applied the "benefit-of-the-doubt" rule to disability claims.
- Who it affects
- Veterans challenging disability decisions face a more limited review of the VA's assessment of closely balanced evidence. For example, a veteran who says medical evidence was evenly balanced must show the VA made a clear factual mistake.
Summary: written with AI from the case record.
What it's about
The Supreme Court held that the VA's determination that evidence is in "approximate balance" is a factual finding subject to clear-error review, rather than a legal conclusion subject to de novo review.
The case defines how much deference the Veterans Court must give the VA when applying the benefit-of-the-doubt rule to disability claims.
Question presented
Must the U.S. Court of Appeals for Veterans Claims ensure that the benefit-of-the-doubt rule in 38 U.S.C. § 5107(b) was properly applied during the claims process in order to satisfy 38 U.S.C. § 7261(b)(1)?
What the Court decided
Holding
The VA’s determination that the evidence regarding a service-related disability claim is in “approximate balance” is a predominantly factual determination reviewed only for clear error. 75 F. 4th 1368, affirmed.
- Result
- Affirmed
The vote
From the opinions
“The VA's determination that evidence is in "approximate balance" is a "predominantly factual determination" reviewed only for clear error.”
What's next
The Federal Circuit's judgment remains in place, and the Veterans Court must apply clear-error review to the VA's approximate-balance determinations. Veterans and the VA will apply that standard in future disability appeals.
Documents
Docket activity
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AI analysis generated: Impact Analysis
AI analysis generated: Opinion Summary
AI analysis generated: Decision Record
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AI analysis generated: Case Briefing
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Audio Recording added: Oral Arguments - Bufkin
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More questions
- What did the Supreme Court rule in Bufkin v. Collins?
- The Court said the VA's approximate-balance decision is mainly factual. The Veterans Court may reverse it only for clear error.
- Who is affected by the Bufkin v. Collins decision?
- Veterans appealing disability claims and the VA are affected. Appeals courts must give the VA more deference on closely balanced evidence.
- What happens next after Bufkin v. Collins?
- The Federal Circuit's decision stands. The Veterans Court will use clear-error review in future cases involving the benefit-of-the-doubt rule.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.