## Facts

- Honorably discharged veterans received educational assistance subject to a 10-year use period after separation from service.
- The veterans did not use all benefits within the 10-year delimiting period and sought extensions.
- They asserted that alcoholism prevented timely use of benefits and qualified as a disabling “physical or mental disorder.”
- Federal law permitted extensions only if the disorder was not the result of the veteran’s “willful misconduct.”
- A VA regulation classified “primary” alcoholism (not attributable to an underlying psychiatric disorder) as “willful misconduct,” and the VA denied extensions on that basis.
- The veterans alleged the VA’s categorical treatment of primary alcoholism violated § 504 of the Rehabilitation Act, which bars discrimination in federal programs against otherwise qualified handicapped individuals solely by reason of handicap.
- In separate cases, one court of appeals held judicial review was barred by a statutory preclusion of review of VA benefit decisions, while another held review was available but upheld the regulation on the merits; the cases were consolidated for Supreme Court review.

## Issues

1. Whether the statutory bar on judicial review of VA benefits decisions precludes federal-court review of a claim that a VA regulation violates § 504 of the Rehabilitation Act.
2. Whether the VA’s regulation treating primary alcoholism as “willful misconduct,” and denying GI Bill delimiting-period extensions on that basis, violates § 504 of the Rehabilitation Act.

## Decision

- The Court held that the judicial-review preclusion provision did not bar review of the Rehabilitation Act challenge to the VA regulation.
- The Court upheld the VA regulation on the merits, concluding that treating primary alcoholism as willful misconduct for purposes of benefit-extension eligibility did not violate § 504.
- The Court affirmed the judgment sustaining the regulation and reversed the judgment that had dismissed for lack of jurisdiction.

## Legal Principles

- There is a presumption favoring judicial review of administrative action, overcome only by clear evidence of congressional intent to preclude review.
- A statutory bar on review of VA decisions “under” laws administered by the VA does not necessarily extend to claims under generally applicable federal statutes challenging the legality of VA regulations.
- Section 504 prohibits discrimination “solely by reason of” handicap, but it does not compel an agency to disregard program eligibility conditions tied to willful misconduct when Congress has made non-misconduct a condition of entitlement.
- An agency may, consistent with § 504, treat a condition it reasonably characterizes as willfully caused or maintained as disqualifying where the statutory benefit scheme expressly excludes disabilities resulting from willful misconduct.

## Conclusion

Federal courts may hear Rehabilitation Act challenges to VA regulations despite the VA benefits review bar, but the VA may deny GI Bill delimiting-period extensions by classifying primary alcoholism as willful misconduct without violating § 504.


Traynor v. Turnage, 485 U.S. 535 (1988)