Soto v. United States, Docket No. 24-320
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A little-known detail about how one law can push another out of the way is the subject of this case. The Supreme Court looked at two rules for paying special combat benefits to veterans. One law, the Combat-Related Special Compensation statute, says the Secretary of Defense gets to decide who qualifies and how much they receive. An older law, called the Barring Act, set up its own claim process and a six-year deadline.
The justices, speaking through Justice Thomas in a unanimous opinion, said the CRSC rule stands on its own. Because it’s a separate law, it replaces the Barring Act’s steps and time limit. In plain terms, veterans seeking these extra payments will follow the newer CRSC path and won’t be blocked by the old six-year window.
Summary of the Case
Petitioner Simon Soto, a Marine Corps veteran medically retired in 2006 with a 100 percent VA disability rating for post-traumatic stress disorder, applied in 2016 for "combat-related special compensation" (CRSC). Although the Navy approved his CRSC status, it limited retroactive payments to six years, citing the six-year statute of limitations in the "Barring Act." Soto filed a nationwide class-action suit arguing that the CRSC law itself provides authority to settle claims, thereby displacing the Barring Act's default procedures and time limits. The district court ruled in favor of Soto's class, but the Federal Circuit reversed. The Supreme Court then agreed to hear the case to resolve whether the CRSC law displaces the Barring Act.
Opinion of the Court
Justice Thomas, writing for a unanimous Court, affirmed that the CRSC law provides an independent settlement mechanism and thus displaces the Barring Act. The Court defined "settlement" of Government claims as involving two key powers: determining if a claim is valid and calculating the amount owed. The Court emphasized that Congress doesn't need to use the specific word "settle" to grant settlement authority.
The CRSC law gives military department Secretaries authority to administer these benefits: it directs them to consider whether each applicant is eligible (resolving claim validity) and prescribes how to determine the monthly amount payable. Read as a whole, the CRSC law establishes a "self-contained, comprehensive compensation scheme" that authorizes the Secretary to perform both settlement functions, thereby displacing the six-year limitation period.
The Court rejected the Federal Circuit's insistence on requiring explicit settlement language or a specific limitations period. Congress can create a compensation scheme without including a time limit; the absence of such a period reflects a deliberate choice appropriate for a narrowly defined class of beneficiaries. The Court also dismissed the Government's policy concerns, finding that the statutory text and structure were sufficient to resolve the case.
How Veterans' Benefits Laws Override General Time Limits
At the heart of this case is the relationship between the Barring Act's default claims-settlement system and the special law Congress created for combat-related compensation. The Barring Act serves as a fallback—authorizing government agencies to "settle" certain military-pay claims and imposing a six-year deadline—unless "another law" provides settlement authority.
Congress doesn't need to explicitly label a statute as a "settlement" law. Instead, courts look at whether the law assigns an agency to (1) evaluate if claims are valid and (2) calculate how much is owed. The CRSC law includes both elements: it directs the Secretary to "consider" eligibility and instructs how to "determine" the monthly payment amount.
The absence of a time limit in the CRSC law is significant: it shows Congress chose not to impose deadlines for this special category of combat-disabled veterans. This structure indicates a legislative decision to completely replace the Barring Act's framework, even without using the word "settle" or specifying an alternative time limit.
The Court's analysis highlights an important principle of statutory interpretation: when Congress creates a specific, self-contained benefits system that includes both elements of settlement authority, that law governs—regardless of whether it contains traditional legal terminology or deadlines. The Soto decision reinforces that a law's effect comes from its text, context, and structure, not from specific magic words.