Martin v. Brown

John Martin was a military veteran. After John’s death, his wife, Mary Ann Martin (plaintiff), applied for veteran pension benefits. Mary Ann applied for both (1) a lump-sum payment of the accrued veteran pension benefits John was entitled to at the time of his death and (2) monthly death-pension benefits. The Department of Veterans Affairs (VA) (defendant) granted Mary Ann both the lump-sum payment and ongoing monthly death-pension benefits. However, after Mary Ann received the lump-sum payment, the VA reduced her monthly death-pension entitlement to account for the income she received from the lump-sum payment. Mary Ann challenged the reduction, arguing that the lump-sum payment should be excluded from her annual income calculation for death-pension benefit purposes because it was a payment of benefits owed to John under Chapter 15 of the Veterans’ Benefits statute. Chapter 15 was the veteran pension provision, and it specifically stated that benefits payable under Chapter 15 were excluded from the annual income calculation. The VA countered, arguing that the lump-sum payment of John’s veteran pension benefits should not be excluded from Mary Ann’s annual income calculation because the lump sum was paid pursuant to Chapter 51, the accrued benefits provision, and not Chapter 15, the veteran pension provision. The Board of Veterans’ Appeals affirmed the death-pension benefit reduction. Mary Ann appealed.