In re A Proposed Amendment to Rule 26(b)

12 Vet. App. 432, 1998 WL 1083790
CourtUnited States Court of Appeals for Veterans Claims
DecidedApril 24, 1998
DocketNo. 98-425
StatusPublished
Cited by4 cases

This text of 12 Vet. App. 432 (In re A Proposed Amendment to Rule 26(b)) 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
In re A Proposed Amendment to Rule 26(b), 12 Vet. App. 432, 1998 WL 1083790 (Cal. 1998).

Opinion

MEMORANDUM AND ORDER

PER CURIAM:

On February 19, 1998, the Chairman of this Court’s Rules Advisory Committee submitted to the Court on behalf of a majority of the Rules Advisory Committee, in response to a December 1, 1997, transmittal from the Court, a proposed amendment to Rule 26(b) of the Court’s Rules of Practice and Procedure (Rules), which addresses the matter of [433]*433extension of time for certain filings. (The text of that proposed amended Rule is included in an Appendix to this Memorandum and Order.) The Rules Advisory Committee was not unanimous and included three dissents with its report.

The Court’s current rule derives from Rule 26(b) of the Federal Rules of Appellate Procedure and provides:

The Court, on its own initiative or on motion of a party for good cause shown, may extend the time prescribed by these rules for doing any act, or may permit an act to be done after the expiration of such time, but the Court may not extend the time for filing a Notice of Appeal.

U.S. Yet.App.R. 26(b).

In its response to the Court, the Rules Advisory Committee expressed the opinion that the time generally consumed in concluding an appeal in this Court is excessive and noted that the Court could remedy the situation, in part, by adopting a stricter policy regarding motions for extensions of time. The Rules Advisory Committee recommended, however, that the Court provide clear standards for considering such motions and that it announce its intended action well in advance of an implementation date so that practitioners could adjust their own procedures. The Court has taken the Rules Advisory Committee’s recommendation under advisement. The instant Memorandum and Order is issued to provide the Court’s practitioners and the public with notice of this pending rulemaking proceeding and its background and of the Court’s serious and growing concern about the matter.

I. Background

The Department of Veterans Affairs (VA) General Counsel has a statutory duty to represent the Secretary before the Court: “The Secretary [of Veterans Affairs] shall be represented before the Court of Veterans Appeals by the General Counsel of the Department”. 38 U.S.C. § 7263(a). This mandatory duty includes taking a position on behalf of the Secretary in every case before the Court. Under the Court’s Rules, the following milestones mark the Secretary’s responsibilities in presenting a case to the Court unless otherwise ordered by the Court: (1) within 60 days after the Notice of Docketing, file a designation of the record (U.S. Vet.App.R. 10(a)); (2) within 30 days after the appellant’s counter designation or statement was due under Rule 10(b), transmit the record on appeal (ROA) (U.S.Vet.App.R. 11(a)(2)); and (3) within 30 days after service of the appellant’s brief or application under the Equal Access to Justice Act (EAJA), 28 U.S.C. § 2412(d), file a response thereto (U.S.Vet.App.R. 31(a), 39(c)). Although much of the impetus for the proposed Rule 26(b) revision derives from multiple extensions of time sought by the Secretary in case after case, the Court does not limit this Memorandum and Order only to extensions sought by the Secretary.

The number of appeals being filed with the Court has increased dramatically. In fiscal year (FY) 1997, there were 2,229 new cases filed — in comparison with 1,620 in FY 1996, 1,279 in FY 1995, and 1,142 in FY 1994. There is reason to believe that the current level of appeals will not decline and may increase. The Court currently has in excess of 2,200 pending cases. The vast majority of these await action by the Secretary on designation and transmittal of the ROA or filing of a brief. In the past year, more than 4,000 extension motions were filed by the Secretary.

The Court finds that the resolution of appeals is being unduly and unreasonably delayed by the thousands of motions filed by the Secretary for extensions of time based on the demands of caseload assignments on the appellate attorneys assigned to representation duties by the General Counsel. The delays occasioned by these motions can serve to frustrate meaningful judicial review, as conferred by right on appellants by chapter 72 of title 38, U.S.Code. In some cases, appellants have died while pursuing appeals as to claims for disability compensation and other VA benefits that do not survive their deaths, see Landicho v. Brown, 7 Vet.App. 42, 47 (1994); see also Zevalkink v. Brown, 102 F.3d 1236, 1243-44 (Fed.Cir.1996) (noting approval of Landicho, supra); in others, appellants who ultimately prevail are not eligible for an award of interest or damages stemming from a previous wrongful denial of ben[434]*434efits by VA, see, e.g., Bagwell v. Brown, 9 Vet.App. 337, 338 (1996); McRae v. Brown, 9 Vet.App. 229, 235 (1996).; Martin (Donald) v. Principi 3 Vet.App. 553, 555 (1992).

II. Court Actions

Because of these concerns the Court has taken a number of actions in the past year:

On February 24, 1997, in a precedential action, the Court expressed its general agreement with an appellant’s opposition to a motion by the Secretary for an extension of time to file a response to the appellant’s brief, which had been filed on November 8, 1996. The appellant there had stated: “The Secretary should ensure that he has sufficient resources available ... to enable his counsel to respond to an Appellant’s opening brief in a timely manner”. Ehringer v. Brown, 10 Vet.App. 103 (1997) (per curiam order). The Court stated as to the General Counsel’s responsibilities:

Such representation must be carried out in a professional manner that satisfies the obligation of counsel for the Secretary “as an officer of this Court”, MacWhorter [v. Derwinski], 2 Vet.App. [655, 657 (1992), appeal dismissed as moot on other grounds, 3 Vet.App. 223 (1992) ]. Whatever other responsibilities may be assigned to the General Counsel by the Secretary, her responsibility with respect to representation in this Court is one mandated by law. A copy of this order will therefore be directed to the General Counsel personally. See United States v. Raimondi 760 F.2d 460, 461 (2d Cir.1985) (government agency must bear ultimate responsibility (including occasionally reassigning a case to another attorney) when staffing pattern in that agency is insufficient to meet judicially imposed requirements).

Ehringer, 10 Vet.App. at 103-04 (emphasis added). The Court then reduced by 25 days the added time that the Secretary was seeking and granted the motion in question. The Court concluded:

No further opposed extensions of time to file a brief will be granted, absent truly exceptional circumstances, which do not include a heavy caseload on the part of counsel for the Secretary in particular or general. See Raimondi supra.

Id. at 104 (emphasis added). Since then, the Court has repeated this Ehringer

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Related

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13 Vet. App. 131 (Veterans Claims, 1999)

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Bluebook (online)
12 Vet. App. 432, 1998 WL 1083790, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-a-proposed-amendment-to-rule-26b-cavc-1998.