Christopher v. United States of America

Donna Christopher, the surviving spouse of deceased veteran James Christopher, filed a claim for dependency and indemnity compensation with the Department of Veterans Affairs. The VA denied her claim, finding that her marriage to the veteran did not meet the statutory duration requirement under 38 U.S.C. § 1318. After the Board of Veterans' Appeals affirmed the denial, Mrs. Christopher appealed to the United States Court of Federal Claims, which granted summary judgment in favor of the government. She then sought review at the Federal Circuit. On January 11, 2018, the appellate court examined whether the VA had improperly interpreted the governing statute and its implementing regulation when calculating the length of the marriage.

The United States Court of Appeals for the Federal Circuit reversed the decision of the Court of Federal Claims, holding that the VA's regulatory interpretation was inconsistent with the plain language of the statute. The case was remanded for further proceedings consistent with the court's construction of the marriage-duration requirement.

Whether the Department of Veterans Affairs erroneously interpreted the statutory requirement for the duration of marriage when determining a surviving spouse's eligibility for dependency and indemnity compensation, specifically regarding the exclusion or inclusion of time after the veteran's death.

The ruling clarified the eligibility standard for surviving spouse benefits, restricting the VA's ability to impose extra-statutory requirements that would disqualify widows and widowers. It reinforced the principle that veterans' benefit statutes should be construed in favor of claimants, providing greater security to surviving family members of deceased service members.