Geraldine B. Lorio v. Douglas A. Collins

CourtUnited States Court of Appeals for Veterans Claims
DecidedMarch 6, 2025
Docket22-1323
StatusPublished

This text of Geraldine B. Lorio v. Douglas A. Collins (Geraldine B. Lorio v. Douglas A. Collins) is published on Counsel Stack Legal Research, covering United States Court of Appeals for Veterans Claims primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Geraldine B. Lorio v. Douglas A. Collins, (Cal. 2025).

Opinion

Case: 22-1323 Page: 1 of 13 Filed: 03/06/2025

UNITED STATES COURT OF APPEALS FOR VETERANS CLAIMS

NO. 22-1323

GERALDINE B. LORIO, APPELLANT,

V.

DOUGLAS A. COLLINS, SECRETARY OF VETERANS AFFAIRS, APPELLEE.

On Appeal from the Board of Veterans' Appeals

(Argued April 3, 2024 Decided March 6, 2025)

April Donahower, with whom Amy F. Odom was on the brief, both of Providence, Rhode Island, for the appellant.

Ronen Morris, with whom Richard J. Hipolit, Deputy General Counsel for Veterans Programs; Mary Ann Flynn, Chief Counsel; Anna Whited, Deputy Chief Counsel; and Jonathan G. Scruggs, Senior Appellate Counsel, all of Washington, D.C., were on the brief for the appellee.

Before BARTLEY, MEREDITH, and JAQUITH, Judges.

BARTLEY, Judge: Appellant Geraldine B. Lorio, surviving spouse of Army veteran Milton Lorio, appeals through counsel a November 19, 2021, decision of the Board of Veterans' Appeals (Board) that found that VA properly withheld retroactive payment of dependency and indemnity compensation (DIC) based on her receipt of Survivor Benefit Plan (SBP) benefits. Record (R.) at 5-18. Her appeal of that issue to this Court is timely, and we have jurisdiction to review the Board decision. See 38 U.S.C. §§ 7252(a), 7266(a). SBP is an annuity program for survivors of military retirees run by the Department of Defense (DOD) and codified under title 10 of the U.S. Code. For the period relevant to this appeal, surviving spouses, except for exceptions not relevant here, could not concurrently receive SBP and DIC payments. This matter was referred to a panel of this Court, with oral argument, 1 to address whether VA had legal authority to withhold Ms. Lorio's DIC payments to prevent concurrent receipt of SBP and DIC benefits. However, we cannot reach that issue since the Board erroneously

1 Lorio v. McDonough, No. 22-1323, Oral Argument [hereinafter Oral Argument]. Available at https://www.youtube.com/watch?v=8rR9jhYNFHI (last accessed Feb. 11, 2025). Oral Argument was held at the Appalachian School of Law in Grundy, Virginia. The Court thanks the students, faculty, and staff at Appalachian School of Law for their hospitality during our visit. Case: 22-1323 Page: 2 of 13 Filed: 03/06/2025

relied on inapplicable legal authority to support its decision, denying her fair process. We therefore remand the case to the Board for readjudication consistent with this decision, including providing legal authority for the withholding and process undertaken in Ms. Lorio's case, addressing evidence obtained by the Secretary after issuance of the Board decision on appeal and arguments raised by the parties regarding that evidence, and whether there has been a proper accounting of withheld benefits.

I. LEGAL LANDSCAPE A. SBP History, DIC Offset, and Notice Requirements Established in 1972, SBP is a subsidized insurance plan that provides annuity payments to survivors of military retirees. See Pub. L. No. 92-425, 86 Stat. 706 (Sept. 21, 1972) (codifying 10 U.S.C. §§ 1447-1455). SBP is administered and partially funded by DOD, with the Defense Finance and Accounting Service (DFAS) as the DOD entity primarily responsible for managing the program. The purpose of SBP is to ensure that surviving dependents continue to have a reasonable level of income following the death of the military retiree. To accomplish its purpose, election into SBP is automatic if the servicemember is married or has a dependent child when becoming eligible to receive retirement pay—unless the servicemember, with spousal concurrence, specifically opts out of the program. 10 U.S.C. § 1448(a)(2). Retirees forego a portion of their retirement pay as premium payments—capped at 6.5%—and, in exchange, DOD pays a monthly annuity to the named beneficiary following the retiree's death, with the full SBP benefit being 55% of the retiree's retirement pay. See 10 U.S.C. §§ 1451(a)(1), 1452(a)(1).2 When Congress created SBP, it required a dollar-for-dollar offset if the SBP annuitant was a surviving spouse also entitled to DIC. Pub. L. No. 92-425 (codifying 10 U.S.C. § 1450(c), later redesignated as 10 U.S.C. § 1450(c)(1)). If the DIC benefit exceeded the SBP benefit, the spouse would receive DIC only. However, if SBP exceeded DIC, the spouse would receive DIC plus a pro-rated SBP benefit consisting of the difference between the two benefits. Congress provided that, when offset applied, surviving spouses would receive a refund of premiums paid by the retiree, see generally 10 U.S.C. § 1450(e) (effective Sept. 21, 1972, to Dec. 31, 2019), with

2 See also, e.g., Congressional Research Service, Military Survivor Benefit Plan: Background and Issues for Congress (Updated Sept. 20, 2024), https://crsreports.congress.gov/product/pdf/R/R45325 (last accessed Mar. 6, 2025).

2 Case: 22-1323 Page: 3 of 13 Filed: 03/06/2025

surviving spouses receiving a full refund when DIC benefits exceeded the SBP annuity and a partial refund when the SBP annuity was reduced by DIC. Id.3 Effective April 1, 2008, Congress imposed notice requirements when there was to be recoupment of paid SBP benefits later determined to be subject to the DIC-SBP offset. National Defense Authorization Act for Fiscal Year 2008, Pub. L. No. 110-181, § 643, 122 Stat. 3, 157 (Jan. 28, 2008) (codifying 10 U.S.C. § 1450(c)(3)). The requirements provided that the relevant DOD Secretary "shall" provide a single notice of the net amount to be recouped or refunded, as applicable; "a written explanation of the statutory requirements for recoupment of the offset amount and for refund of any applicable deductions from retired pay"; a detailed accounting of how the offset recoupment amount and the refunded retired pay deduction were calculated; and "contact information for a person who can provide information about the offset recoupment and retired pay deduction refund processes and answer questions the surviving spouse . . . may have about requirements, processes, and amounts." 10 U.S.C. § 1450(c)(3). B. Roberts v. McDonald This Court previously addressed SBP in Roberts v. McDonald, where the Court reviewed a Board determination that VA had properly withheld a portion of retroactive DIC benefits based on receipt of SBP payments. 27 Vet.App. 108 (2014). The Board relied on 38 C.F.R. § 3.658 as the withholding authority but the Secretary conceded that this was incorrect and proffered that VA's DIC withholding authority stemmed from 38 U.S.C. § 5314, 38 C.F.R. §§ 1.911(a), 1.912a(a), and a 2010 memorandum of understanding (MOU)4 between VA and DOD. Roberts, 27 Vet.App. at 110. The Court remanded the appeal, concluding that reliance on inapplicable authority deprived Ms.

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