On June 12, the Supreme Court issued its opinion in Soto v. United States, a case originally decided by the Federal Circuit. The Court granted review to consider whether a statutory provision governing Combat-Related Special Compensation, 10 U.S.C. § 1413a, provides a settlement mechanism that displaces the default procedures and limitations set forth in the Barring Act. According to the Federal Circuit, “the Barring Act applies to settlement claims” regarding Combat-Related Special Compensation and, as a result, “the six-year statute of limitations contained in the Barring Act applies to CRSC settlement claims.” The Supreme Court, in an opinion authored by Justice Thomas, reversed. According to the Court, “[t]he CRSC statute confers authority to settle CRSC claims and thus displaces the Barring Act’s settlement procedures and limitations period.” This is our opinion summary.
Justice Thomas began by briefly discussing the relevant background of the case:
Title 31 U. S. C. §3702, known as the Barring Act, establishes a default settlement regime for certain claims brought against the Government. The Barring Act subjects most claims to a 6-year limitations period . . . But, the Act includes an exception: If “another law” confers authority to settle a claim against the Government, then that law displaces the Barring Act’s settlement mechanism—including its limitations period—as to that claim . . . The question before us is whether a law providing “[c]ombat-related special compensation” (CRSC) to qualifying veterans confers authority to settle CRSC claims.
Justice Thomas began his analysis by “address[ing] how this Court has construed ‘settlement’ of claims against the Government and what is required for a statute to confer settlement authority.” He explained that “[a] statute confers settlement authority so long as it vests an entity with the power to determine both a claim’s validity and amount due.” Applying this approach here, he explained, “[t]he CRSC statute meets these requirements.” In short, he said, “[t]he statute . . . creates a separate settlement mechanism—i.e., ‘another law’—that displaces the Barring Act’s default settlement procedures, including its limitations period.”
Next, Justice Thomas addressed and rejected the Federal Circuit’s reasoning. He stated that “Congress ‘need not state its intent in any particular way,’ and ‘[w]e have never required that Congress use magic words.'” Moreover, he said, the CRSC “displaces the Barring Act in its entirety irrespective of whether it separately addresses timing.”
Justice Thomas then addressed and rejected the government’s arguments for affirmance. First, he explained, the Court “reject[ed] the Government’s ‘formulations’-focused attempt to limit the ways that Congress may convey settlement authority.” The Court, he said, in paraticular “disagree[d] with the proposition that a settlement mechanism must include a limitations period to displace the Barring Act.” Second, he continued, the Court “decline[d] the Government’s invitation to read additional requirements into the ‘administrative determination of the amount due.'”
Justice Thomas explained how the Court held “only that §1413a’s separate subsections—in combination—create a comprehensive CRSC benefits regime spanning from application to payment, and that, within this framework, Congress has authorized the Secretary concerned to determine both the validity of applicants’ CRSC claims and the amount due on them.” He also noted that, “[e]ven if we thought sound policy called for a narrower carveout to the Barring Act’s procedures than the ‘another law’ exception that Congress enacted, . . . that policy choice is a ‘matte[r] for Congress, not this Court, to resolve.'”
As a result of his analysis, the Court reversed the judgment of the Federal Circuit and remanded the case.