Johnson v. Robison

Supreme Court of the United States · 1974 · Federal Courts

Federal CourtsJudicial ReviewVeterans' BenefitsEqual 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 a Boston hospital. He then applied for educational assistance under the Veterans' Readjustment Benefits Act of 1966. The Veterans' Administration denied the application because the statute limits eligibility to veterans who served on active duty, defined as full-time duty in the Armed Forces. Robison challenged that exclusion as violating the First Amendment and the Fifth Amendment.

Issue

Does 38 U.S.C. § 211(a), which makes the Administrator's decisions final and generally unreviewable, bar federal courts from hearing a constitutional challenge to veterans' benefits legislation itself? If not, does Congress violate the Fifth Amendment or the First Amendment by granting educational benefits to those who served on active duty in the Armed Forces while excluding I-O conscientious objectors who performed alternative civilian service?

Rule

Section 211(a) precludes judicial review of the Administrator's decisions of law or fact made in administering veterans' benefits statutes, but it does not bar suits challenging the constitutionality of the statutes enacted by Congress. A benefits classification survives Fifth Amendment review if it is reasonable, not arbitrary, and rests on a ground of difference having a fair and substantial relation to at least one statutory objective. A neutral statute that imposes only an incidental burden on religious exercise is valid where justified by substantial governmental interests and not designed to interfere with religion.

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

In Seattle, Noah Patel applied to the Federal Service Benefits Office for a training stipend created by a federal statute for former maritime security officers. The agency denied his claim because it found he had served only 11 months, and Noah then sued in federal district court arguing both that the agency miscounted his months and that the statute itself violates the Fifth Amendment by excluding civilian emergency volunteers.

Assuming the statute contains a no-review provision making the agency's decisions on questions of law or fact final and conclusive, which claim may the district court hear?

Explanation. The majority distinguished between review of an administrator's decision under the statute and a constitutional attack on Congress's enactment. A no-review clause bars judicial review of agency decisions of law or fact made in administering the benefits program, such as counting service months, but it does not bar a suit challenging the constitutionality of the statutory classification itself.