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.
Vote & lineup9–0 (unanimous) on the judgment. Thomas delivered the opinion for a unanimous Court (9).
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.