Supreme Court of the United States

Brown v. Gardner

December 12, 1994513 U.S. 115

Summary

The unanimous Court, in an opinion by Justice Souter, held that 38 U. S. C. § 1151 does not require proof of VA fault and that the regulation imposing a fault-or-accident requirement is inconsistent with the statute. The statutory language requires a causal connection between treatment and additional disability, not negligence. Neither congressional reenactment, subsequent legislative silence, nor the regulation’s longevity justified departing from the statute’s clear meaning. The Court affirmed the Federal Circuit’s judgment. There were no separate opinions.

Holding

  • Whether § 1151 authorizes the VA’s fault-or-accident requirement.. The regulation’s fault-or-accident requirement is inconsistent with § 1151; the statute requires causation but does not require proof of VA fault.
  • Whether reenactment and legislative silence ratified the VA’s interpretation.. Neither congressional reenactment nor subsequent legislative silence validated the regulatory fault requirement.
  • Whether the regulation’s longevity entitled it to judicial deference.. The regulation’s longstanding existence did not warrant deference because it contradicted the statute’s plain language.

Docket 93-1128

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