## Facts

- Congress enacted the Veterans’ Readjustment Benefits Act of 1966, providing educational benefits to individuals who served in the armed forces.
- The Act categorically excluded conscientious objectors who, though exempted from military service, completed required alternative civilian service.
- Robison, a Class I–O conscientious objector who performed alternative service, filed a class action challenging the exclusion.
- He alleged the exclusion violated the Free Exercise Clause of the First Amendment and the equal-protection component of the Fifth Amendment’s Due Process Clause.
- Federal officials argued the suit was barred by 38 U.S.C. § 211(a), which restricts judicial review of Veterans’ Administration benefits decisions.
- The district court held § 211(a) did not bar constitutional challenges, rejected the First Amendment claim, sustained the Fifth Amendment claim, and ordered benefits extended to the class.

## Issues

1. Whether 38 U.S.C. § 211(a) bars federal courts from hearing constitutional challenges to veterans’ benefits legislation.
2. Whether excluding conscientious objectors who performed alternative civilian service from educational benefits violates the equal-protection component of the Fifth Amendment.
3. Whether the exclusion violates the Free Exercise Clause of the First Amendment.

## Decision

- The Supreme Court held that § 211(a) does not bar constitutional challenges to veterans’ benefits statutes; it bars review of individual administrative benefits determinations made in administering such statutes.
- The Court held the exclusion does not violate the Fifth Amendment because the classification between military service and alternative civilian service is rationally related to legitimate governmental objectives.
- The Court held the exclusion does not violate the First Amendment because any burden on religious exercise is incidental and not the product of a legislative design to inhibit religion.
- Justice Douglas dissented, reasoning that conscientious objectors who performed required alternative service should receive the same educational benefits as others who served the national interest in noncombat roles.

## Legal Principles

- Statutes precluding judicial review of agency benefits decisions do not, absent clear congressional intent, foreclose federal jurisdiction over constitutional challenges to the governing statute itself.
- Allocations of government benefits that do not involve a suspect classification or a fundamental right are evaluated under rational-basis review and upheld if reasonably related to legitimate governmental purposes.
- Congress may rationally distinguish between military service and alternative civilian service based on differences in disruption, obligations, and the goal of encouraging military service.
- A benefits scheme that is neutral as to religion and not aimed at religious practice does not violate the Free Exercise Clause merely because it has incidental adverse effects on religiously motivated conduct.

## Conclusion

The Court permitted federal courts to hear constitutional attacks on veterans’ benefits legislation notwithstanding § 211(a), and it upheld Congress’s decision to limit educational benefits to armed-forces veterans while excluding conscientious objectors who completed alternative civilian service.


Johnson v. Robison, 415 U.S. 361 (1974)