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Johnson v. Robinson

Supreme Court of the United States · 1974 · Constitutional Law

Constitutional LawVeterans' benefitsJudicial reviewEqual protectionFree Exercise38 U.S.C. § 211(a)judicial reviewconstitutional challenge

Facts

Robison was a draftee classified I-O as a conscientious objector and, instead of serving in the Armed Forces, completed two years of required alternative civilian service at Peter Bent Brigham Hospital in Boston. He then applied for educational assistance under the Veterans' Readjustment Benefits Act of 1966. The Veterans' Administration denied the application because the Act defines an eligible veteran as one who served on active duty, and active duty means full-time duty in the Armed Forces. Robison challenged that exclusion as violating the Free Exercise Clause and equal protection as incorporated in the Fifth Amendment.

Issue

Does 38 U.S.C. § 211(a) bar federal courts from considering a constitutional challenge to veterans' benefits legislation? If not, does Congress violate the Fifth Amendment or the Free Exercise Clause by limiting veterans' educational benefits to those who served on active duty in the Armed Forces and excluding I-O conscientious objectors who performed alternative civilian service?

Rule

Section 211(a), which makes final the Administrator's decisions on questions of law or fact under laws administered by the Veterans' Administration, does not preclude judicial review of constitutional attacks on the validity of veterans' benefits statutes themselves. A statutory classification in this context is valid if it has a rational basis bearing a fair and substantial relation to at least one legitimate legislative objective, and an incidental burden on religion does not violate the Free Exercise Clause when the legislation advances neutral, secular governmental interests and is justified by substantial governmental interests.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Seattle, Noah Kim applied to the Veterans Support Bureau for housing assistance under a federal veterans statute. After the Bureau denied his application because the statute excludes people who completed mandatory civilian national service instead of active military duty, Noah sued in federal court alleging the statutory exclusion itself violates the Fifth Amendment.

Should the federal court dismiss for lack of jurisdiction under a statute providing that the agency's decisions on any question of law or fact under veterans-benefits laws are final and unreviewable?

Explanation. The majority construed the no-review provision to bar review of agency decisions of law or fact made in administering veterans-benefits statutes, not constitutional attacks on the validity of the statute enacted by Congress. Noah is not contesting how the agency interpreted evidence or applied the statute to him; he attacks the statutory exclusion itself under the Constitution. That kind of claim is reviewable.