Opinion of the Court
increase a pension that had been awarded based on anticipated income); §5110(i) (permitting retroactive benefits when “any disallowed claim is readjudicated and thereafter allowed on the basis of new and relevant evidence resulting from the correction of” certain military records). Yet despite its attention to fairness, Congress did not throw the door wide open in these circumstances or any other. In all but one instance, Congress capped retroactive benefits at roughly one year.[1]
This pattern matters. That Congress accounted for equitable factors in setting effective dates strongly suggests that it did not expect an adjudicator to add a broader range of equitable factors to the mix. And its decision to consistently cap retroactive benefits strongly suggests that it did not expect open-ended tolling to dramatically increase the size of an award. When Congress has already considered equitable concerns and limited the relief available, “additional equitable tolling would be unwarranted.” Beggerly, 524 U. S., at 48–49.
Section 5110(b)(4), another disability-related exception to
- ↑ Thirteen of the exceptions, including §5110(b)(1), allow an effective date up to one year before the application-receipt date. See, e.g., §5110(b)(3) (“The effective date of an award of increased compensation shall be the earliest date as of which it is ascertainable that an increase in disability had occurred, if application is received within one year from such date” (emphasis added)). Two exceptions contemplate the possibility that the effective date of an award might stretch up to one day short of 13 months before the application-receipt date. See §§5110(d) (“The effective date of an award of death compensation, dependency and indemnity compensation, or death pension for which application is received within one year from the date of death shall be the first day of the month in which the death occurred”), (e)(1). The only one offering more than 13 months of retroactive benefits concerns the death of an active-duty servicemember. This provision permits an award of death compensation to be effective as of the month of death, no matter how long ago the death occurred—but still, retroactive benefits are permitted only if the VA receives the application within one year of the military’s entry of a report or finding of the servicemember’s death. §5110(j).
