Supreme Court Rules Against Veterans in “Benefit of the Doubt” Case
October 10, 2025
In a March 2025 case, the United States Supreme Court ruled that the U.S. Court of Appeals for Veterans Claims is not required to review the application of the “benefit of the doubt” rule by the Department of Veterans Affairs. This result is likely to affect benefits rulings for many veterans nationwide.
The Facts of the Case
The case, Bufkin v. Collins, incorporated arguments from two veterans. Joshua Bufkin served in the Air Force from 2005 to 2006. Norman Thornton served from 1988 to 1991.
About seven years after leaving military service, Bufkin filed a disability claim for post-traumatic stress disorder. He described significant marital stress during his time in the service, including threats from his wife that she would commit suicide if he remained in the military. Facing these difficulties, Bufkin argued, he failed to complete training as a military policeman. He ultimately sought a hardship discharge, which the Air Force granted.
Bufkin filed for VA health care and benefits, stating he had service-related PTSD as a result of these difficulties. VA doctors disagreed about both the PTSD diagnosis and whether Bufkin’s complaints were service-related. The VA rejected his claim for benefits.
Thornton received a 10 percent disability rating for PTSD connected to his service in the Gulf War. The rating was later raised to 50 percent. Thornton argued that the rating should have been higher.
The Veterans Board of Appeals weighed the evidence in both cases. It found that the evidence in Bufkin’s case conflicted, as doctors did not share consistent views about Bufkin’s diagnosis or its connection to his military service. In Thornton’s case, the board found his evidence didn’t support a higher disability rating.
In both cases, the board did not apply the “benefit of the doubt” standard. This standard holds that veterans should receive benefits when the evidence in their case does not weigh clearly in favor of either side.
The Veterans Court of Appeals reviewed the case. The Court of Appeals held that the board didn’t err when it denied benefits to either Bufkin or Thornton, but it did not examine the “benefit of the doubt” question.
The Supreme Court’s Holding
Bufkin and Thornton appealed to the US Supreme Court. In their petition, they argued that the law requires veterans to receive the benefit of the doubt. The Board’s failure to provide the benefit of the doubt and the Court of Appeals’ failure to consider that mistake were both errors, they claimed.
In a 7-2 decision, the Supreme Court disagreed. In an opinion written by Justice Clarence Thomas, the Court held that the “benefit of the doubt” question is fact-based “and thus subject to clear-error review.”
A “clear-error” review doesn’t dive too deeply into the facts or the record, and it involves no additional investigation by the appeals court. Rather, the court decides, based on the case records, whether a lower court has made a “clear error” or obvious mistake. If an issue is subject to interpretation or is not an obvious violation of the law, the appeals court will likely let it stand.
The Supreme Court held the VA Court of Appeals may, but is not required to, examine “benefit of the doubt” decisions beyond examining them for clear error. To require more would “establish a new standard of review for challenges to the VA’s application of the benefit-of-the-doubt rule,” wrote the Court. The Court held that the law creating the benefit of the doubt rule does not go so far as to create this standard of review.
Justices Jackson and Gorsuch dissented. Writing separately, Justice Jackson argued that veterans are entitled to an opinion in their favor on “any reasonable doubt on a material issue.” The Court’s clear error standard, Jackson wrote, fails to uphold Congress’s intent. If the VA Court of Appeals is not obligated to review benefit-of-the-doubt decisions, wrote Jackson, then veterans lose a key legal protection.
Where to Turn For Help
The outcome of Bufkin v. Collins is likely to affect many veterans whose benefits cases offer roughly equal evidence for or against granting benefits. The “benefit of the doubt” rule is intended to resolve those cases in favor of the veterans. Without a meaningful way to challenge a negative ruling, however, veterans may lose access to needed benefits.
If you’re dealing with a tough fight for benefits, talk to an experienced veterans disability benefits attorney today. Your lawyer can help you build a strong case that weighs clearly in your favor.