Page:Arellano v. McDonough.pdf/2

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ARELLANO v. MCDONOUGH

Syllabus

presumes that federal statutes of limitations are subject to equitable tolling. See Irwin v. Department of Veterans Affairs, 498 U. S. 89, 95–96. But this presumption is rebutted if equitable tolling is inconsistent with the statutory scheme. Here, the Secretary of the VA argues that §5110(b)(1) is not a statute of limitations and that, even if it were, any applicable presumption in favor of equitable tolling is rebutted by the statutory text and structure. The Court need not decide whether §5110(b)(1) is a statute of limitations. Even assuming that the exception sets a limitations period, there exists “good reason to believe that Congress did not want the equitable tolling doctrine to apply.” United States v. Brockamp, 519 U. S. 347, 350.

Section 5110(b)(1) operates as a limited exception to §5110(a)(1)’s default rule, which states that “the effective date of an award … shall be fixed in accordance with the facts found, but shall not be earlier than the date of receipt of application therefor.” The default rule applies “[u]nless specifically provided otherwise in this chapter”—a clause indicating that Congress enumerated an exhaustive list of exceptions, with each confined to its specific terms. According to the terms of the exception in §5110(b)(1), “[t]he effective date of an award of disability compensation to a veteran shall be the day following the date of the veteran’s discharge or release if application therefor is received within one year from such date of discharge or release.” Equitably tolling this provision would depart from the terms that Congress “specifically provided.” §5110(a)(1).

The structure of §5110—which sets out 16 exceptions that explain when various types of benefits qualify for an effective date earlier than the default—reinforces Congress’s choice to set effective dates solely as prescribed in the text. These exceptions do not operate simply as time constraints, but also as substantive limitations on the amount of recovery due, a structure strongly indicating that “Congress did not intend courts to read other unmentioned, open-ended, ‘equitable’ exceptions into the statute that it wrote.” Brockamp, 519 U. S., at 352. That many of the specific exceptions reflect equitable considerations heightens the structural inference, as does the fact that Congress generally capped retroactive benefits at roughly one year. When, as here, Congress has already considered equitable concerns and limited the relief available, “additional equitable tolling would be unwarranted.” United States v. Beggerly, 524 U. S. 38, 48–49. Although hard and fast limits on retroactive benefits can create harsh results, Congress has the power to choose between rules, which prioritize efficiency and predictability, and standards, which prioritize optimal results in individual cases. Cf. Brockamp, 519 U. S., at 352–353. Congress opted for rules in this statutory scheme, and an equitable extension of §5110(b)(1)’s 1-year grace period would disrupt that choice. Pp. 3–9.