Springs v. Braithwaite

CourtDistrict Court, District of Columbia
DecidedMarch 11, 2022
DocketCivil Action No. 2020-3244
StatusPublished

This text of Springs v. Braithwaite (Springs v. Braithwaite) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Springs v. Braithwaite, (D.D.C. 2022).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

KENNETH SPRINGS, et al.,

Plaintiff,

v. Civil Action No. 20-3244 (RDM)

CARLOS DEL TORO, et al., 1

Defendant.

MEMORANDUM OPINION AND ORDER

This case concerns the disability ratings assigned to former members of the U.S. Navy and

Marine Corps who suffered from medical conditions that rendered them unfit for continued

military service. Dkt. 1 at 3–4 (Compl. ¶ 8). These ratings impact, among other things, service

members’ eligibility for benefits following their separation from the military. Id. at 3 (Compl.

¶ 7); AR 3231–32. Plaintiffs, two former members of the U.S. Navy and Marine Corps, allege

that they were “assigned a combined disability rating for these [medical] conditions that was

lower than the combined disability rating required by the relevant statutes and regulations.” Dkt.

1 at 2 (Compl. ¶ 2). Plaintiffs have moved to certify a class of similarly situated individuals. Dkt.

34. In response, Defendants, the Secretary of the Navy and the United States, acknowledge that

this suit may proceed as a class action but propose alterations to the class definition, Dkt. 35, to

which Plaintiffs have agreed in their reply, Dkt. 37.

For the reasons that follow, the Court will GRANT Plaintiffs’ motion as modified.

1 The Court automatically substitutes the current Secretary of the Navy in the case caption. See Fed. R. Civ. P. 25(d) (providing that “when a public officer . . . ceases to hold office while the action is pending . . . [t]he officer’s successor is automatically substituted as a party”). I. BACKGROUND

A. Statutory and Regulatory Background

Each branch of the military must develop a process for evaluating service members’

medical conditions, their ability to continue service, and—if unable to serve—their eligibility for

retirement benefits or severance payments. See 10 U.S.C. § 1216(a). One purpose of this

evaluation is to generate a disability rating percentage, which is then used to determine whether

the service member is entitled to disability retirement and retirement benefits. See id. § 1201(a)–

(b). To receive such benefits, the service member’s rating percentage must exceed 30%, id.

§ 1201(b)(3)(B); otherwise, the service member receives only a one-time severance payment, with

no continuing benefits, id. § 1203(a)–(b). These ratings are based on “the schedule for rating

disabilities in use by the Department of Veterans Affairs (‘VA’),” and, “[i]n making a

determination of the rating of disability[,] . . . the Secretary concerned shall take into account all

medical conditions, whether individually or collectively, that render the member unfit to perform

the duties of the member’s office, grade, rank, or rating.” Id. § 1216a.

In this action, Plaintiffs challenge the regulatory regime that implemented these statutory

mandates for the Department of Navy, SECNAVINST 1850.4E, which includes both the Navy

and the Marine Corps, 50 U.S.C. § 3004(b); see also Jud. Watch, Inc. v. U.S. Dep’t of Def., No.

19-cv-1384, 2021 WL 270503, at *3 (D.D.C. Jan. 27, 2021) (“[T]he Marine Corps is part of the

Department of the Navy.”). In June 27, 2019, however, the Secretary of the Navy, on behalf of

the Navy and the Marine Corps, issued new regulations for making disability determinations, AR

3245; see SECNAVINST 1850.4F, and—although the new regime retains much of the structure

of the prior one—the relief Plaintiffs seek applies only to the former scheme, Dkt. 37 at 5. Under

that scheme, the Secretary of the Navy assigned to the Physical Evaluation Board (“PEB”) “the

2 responsibility to act on [his] behalf to make determinations of fitness for continued naval service,

entitlement to benefits, disability ratings, and the disposition of [s]ervice members referred to it”

from both the Navy and the Marine Corps. AR 3234. The process itself was known as the

Disability Evaluation System (“DES”), and service members required a referral into the DES

from a medical provider after the “provider recognize[d] that a wound, illness, or injury w[ould]

not improve to the point of returning a [service] member to full duty.” AR 3234–35.

A medical referral initiated the first of the three steps involved in the DES. At step one,

the claim went to the Medical Evaluation Board (“MEB”), which “review[ed] the member’s entire

medical treatment record and often add[ed] other conditions for which the member may have been

treated for or that the MEB believe[d] [affected] his or her ability to perform duties.” AR 3235.

The goal was to determine “whether the [s]ervice member ha[d] medical conditions that . . .

prevent[ed] him or her from reasonably performing assigned duties;” if the MEB answer[ed] that

question in the affirmative, “the case [wa]s referred to” to the PEB for “[t]he second of the three

DES phases.” AR 3236.

At the second step, “PEB administrators ensure[d] the file [wa]s complete and sen[t] it to a

PEB Medical Officer” who conducted “an Informal PEB,” or “a records review.” Id. The

Medical Officer “review[ed] the entirety of the case” and assigned each “referred condition” one

of the following categories: “Category I (Unfitting), Category II (Contributing to the Unfitting

Condition), Category III (Not Separately Unfitting and Does Not Contribute to the Unfitting

Condition), and Category IV (Does Not Constitute a Physical Disability).” Id. “If the Medical

Officer determined the member had a medical condition or medical conditions that prevented him

or her from reasonably performing duties either singularly, collectively, or through the combined

effect of two or more conditions, those conditions were assigned to Category I.” Id. Any such

3 condition was known as an “unfitting condition.” AR 3239–40. All other referred conditions

were placed in Category II, III, or IV. AR 3239.

As relevant to this litigation, if a Medical Officer determined that a service member was

unfit for service, the Medical Officer assigned the service member a disability rating. See

SECNAVINST 1850.4E, § 3801(b); 10 U.S.C. § 1216(a). This disability rating ranged from 0%

to 100%, and “represent[ed], as far as can practicably be determined, the average impairment in

civilian occupational earning capacity resulting from certain diseases and injuries, and their

residual conditions.” SECNAVINST 1850.4E, § 3801(b); see also SECNAVINST 1850.4E,

§ 2063. The Medical Officer issued a disability rating for each Category I condition, but,

crucially for present purposes, “the Navy did not separately rate Category II conditions” while the

regulatory scheme relevant to this litigation remained in place. AR 3241. This meant that,

although the disability ratings issued for various Category I conditions might be aggregated to

create a service member’s combined disability rating, he or she would not receive the benefit of

any additional rating based on Category II conditions. AR 3243–44. And, as noted above, it was

the total percentage rating that determined whether a service member who was unfit for service

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