In 1984, Congress enacted a new “GI Bill” to provide limited financial assistance to veterans of the United States’ military services seeking a college education. In 2008, Congress enacted a broader college education benefit program for veterans who served after September 11, 2001, including those veterans who were still eligible for the more limited benefits under the 1984 GI Bill. In Rudisill v. McDonough, Secretary of Veteran Affairs, decided on April 16, 2024, the Court held that under the text of the latter statute, the two benefit programs were to operate independently of each other, so that a veteran eligible for benefits under both programs could freely choose which program’s benefits to pursue, in any order he or she chose, without impairing his or her continuing entitlement to benefits under the other program (subject to an aggregate maximum benefit over both). The vote on the Court was 7-2, with Justices Thomas and Alito dissenting.
COMMENT: Justices Thomas and Alito correctly interpreted the text of the 2008 legislation; the majority did not. The text of the 2008 legislation explicitly required the “coordination” of the two benefit programs, ordering the deduction of benefits obtained under the older program from the benefit entitlement of the newer program. Of particular interest here is the fact that neither side of the debate argued its perception of Congress’s intents and purposes behind the 2008 legislation. It was obviously not intended to replace the 1984 legislation, which remained in full effect. The technical or semantical meaning of specific words in a larger text (the sole topic of discussion by both sides) do not completely answer the more important questions, under a republican government, of the legislature’s intent or purpose. Only the context of the larger document in its entirety, and the historical purpose of that document provide a complete answer to those all-important questions.
Dan Rhea
RECENT RULINGS 