Soto, Individually and on Behalf of All Others Similarly Situated v. United States
No. 24-320 · Decided June 12, 2025 · reversed and remanded
Does the statute providing "combat-related special compensation" (CRSC), 10 U. S. C. § 1413a, confer authority to settle claims against the Government? The CRSC statute confers authority to settle claims and thus displaces the Barring Act's settlement procedures and limitations period.
CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FEDERAL CIRCUIT · Argued April 28, 2025
Parties — Petitioner: SOTO, individually and on behalf of all others similarly situated · Respondent: UNITED STATES
Vote & lineup9–0 (unanimous) on the judgment. Thomas delivered the opinion for a unanimous Court (9).
Who prevailed — Petitioner prevailed in that the Court held the Barring Act's six-year limitations period does not apply to CRSC payments.
The question

Does the statute providing "combat-related special compensation" (CRSC), 10 U. S. C. § 1413a, confer authority to settle claims against the Government? If so, does this authority displace the default settlement procedures and six-year limitations period established by the Barring Act, 31 U. S. C. § 3702? Specifically, the Court must determine if the CRSC statute constitutes "another law" under 31 U. S. C. § 3702(a).

Petitioner's argument
  • The CRSC statute (10 U. S. C. § 1413a) constitutes "another law" that provides its own settlement mechanism.
  • Because it provides a separate mechanism, the six-year limitations period of the Barring Act does not apply to these claims.
  • Petitioner is entitled to retroactive CRSC payments dating back to January 1, 2008, rather than being limited to six years.
Respondent's argument
  • The CRSC statute only establishes eligibility for payments and does not explicitly grant the authority to "settle" claims.
  • To displace the Barring Act, a statute must use "hallmark formulations"—such as language regarding claims being allowed or disallowed—or provide a specific limitations period.
  • Allowing the CRSC statute to displace the Barring Act through silence on timing would destabilize various Government programs.
  • The statute does not permit the Secretary concerned to determine the amount due because it lacks explicit instructions for auditing and adjusting accounts.
The decision
  • The Court held that 10 U. S. C. § 1413a confers authority to settle CRSC claims, thereby displacing the Barring Act's settlement procedures and limitations period under 31 U. S. C. § 3702(a).
  • Relying on *Illinois Surety Co. v. United States ex rel. Peeler*, the Court defined "settle" as the power to both "determine upon the validity of" a claim and "determine . . . the amount due."
  • The Court noted that Congress does not need to use "magic words" or specific language like the term "settle" to confer this authority, citing *Department of Agriculture Rural Development Rural Housing Service v. Kirtz*.
  • To determine if a law displaces the Barring Act, courts must examine the text, context, and structure of "the entire statutory scheme," per *Winkelman v. Parma City School Dist.*
  • The Court found that 10 U. S. C. § 1413a(d) authorizes the Secretary concerned to determine validity because requiring the Secretary to "conside[r]" whether an applicant is "eligible" is tantamount to determining a claim's validity since the Secretary "shall pay" each eligible veteran under § 1413a(a).
  • The Court found that 10 U. S. C. § 1413a(b)(1)–(3) confers authority to determine the amount due by prescribing how monthly payments are determined and setting a "maximum amount."
  • The Court rejected the Federal Circuit's requirement that a statute must provide its own specific limitations period to displace the Barring Act, stating that a settlement mechanism does not require a timing limit.
  • The Court dismissed the Government's "hallmark formulations" test as another version of a "magic words" test and rejected the argument that auditing requirements must be explicitly stated for a statute to authorize the determination of an amount due.