Traynor v. Turnage

Eugene Traynor (plaintiff) and James McKelvey (plaintiff) both began drinking as children and ultimately developed primary alcoholism, meaning alcoholism not caused by underlying mental illness. Both Traynor and McKelvey were honorably discharged active-duty military veterans. After discharge, both Traynor and McKelvey were repeatedly hospitalized for their alcoholism or related complications. Eventually, both Traynor and McKelvey stopped drinking and were considered recovering alcoholics. Using the GI Bill’s educational benefits, both Traynor and McKelvey attended educational institutions after being discharged from the military; however, their alcoholism prevented them from finishing their educations within the GI Bill’s 10-year time limit. Under the GI Bill, veterans who were unable to complete their education within the 10-year time limit because of a physical or mental disability not caused by “willful misconduct” were exempt from the 10-year limit. Pursuant to that exception, both Traynor and McKelvey applied for extensions of their educational benefits, arguing that (1) they were unable to complete their educations within the 10-year time limit because they were disabled by alcoholism; (2) their alcoholism was not caused by “willful misconduct”; and (3) Section 504 of the Rehabilitation Act prohibited veterans from being denied federal benefits, like GI Bill’s educational benefits, solely because of disability. The Veterans’ Administration (VA) (defendant) refused to extend Traynor’s and McKelvey’s educational benefits because the VA defined primary alcoholism as a disability caused by “willful misconduct.” The district court reversed, holding that alcoholism was a disability and that the Rehabilitation Act prohibited the VA from denying Traynor and McKelvey benefits because of their disabilities. The District of Columbia Circuit reversed on appeal, holding that the VA could classify alcoholism as a willfully caused disability and use that classification to deny benefits. Traynor and McKelvey appealed.