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Paralyzed Veterans of Am. v. Sec'y of Veterans Affairs
345 F.3d 1334 (Fed. Cir. 2003) ; Clearinghouse Number: 55422
Description
Federal Circuit Rejects Challenge to All But One Regulation Implementing Veterans Claims Assistance Act
Abstract
The Federal Circuit held that 38 C.F.R. § 3.159(b)(1) was
invalid because it imposed on veterans’ benefits claimants an
arbitrary new deadline that was not a reasonable exercise of the
authority of the Department of Veterans Affairs (VA). Petitioner
veterans’ service organizations challenged the validity of
various VA regulations implementing the Veterans Claims Assistance
Act of 2000, which clarified VA’s duty to assist claimants.
Among other provisions, the Act no longer required that a claimant
establish a well-grounded claim before the VA provided assistance.
Petitioners claimed that the regulations at issue were arbitrary,
capricious, and an abuse of discretion; lacked a statutory basis;
and were inconsistent with congressional intent. The court held
that 38 C.F.R. § 3.159(b)(1), which required claimants to
respond to VA’s request for necessary information and
evidence within thirty days, was an unreasonable exercise of
VA’s discretion. The regulation required the VA, if a
claimant had not responded to its request within thirty days, to
decide the claim on the basis of all the information and evidence
in the file before the statutory one-year period to submit
additional evidence expires. The court found that the plain
language of the statute gave claimants one year to submit the
requested evidence. However, the court rejected petitioners’
challenge to several other regulations, including ones on medical
examinations for veterans seeking to reopen claims, notification to
claimants of VA’s inability to obtain records, “new and
material” evidence, and when medical examinations are
necessary.
