The Veterans Administration (VA) (defendant) provided compensation to military veterans who suffered from disabilities resulting from injury in the line of duty. The VA’s original regulation provided for an informal process by which veterans could apply for compensation. Later, however, the VA proposed a new rule that sought to standardize and modernize the claim-initiation process. The proposed rule would have allowed claimants to establish a claim’s effective date through the submission of an electronic application. The VA received a number of comments regarding the proposed rule. Some commenters expressed concerns over the claim process. In response to the comments, the VA promulgated a final rule, which established a different claim process, known as an intent-to-file process. This process would have allowed applicants to establish a claim’s effective date by submission of a written intent to file a claim on a standard VA form, or through several other means. The American Legion and other veterans’ organizations (plaintiffs) brought suit, arguing that the final rule’s intent-to-file provision should be set aside because the VA did not follow the proper notice-and-comment rulemaking procedures required by the Administrative Procedure Act (the act). The VA countered that the final rule was a logical outgrowth of the proposed rule and thus did not violate the act’s requirements. The case was heard by the United States Court of Appeals for the Federal Circuit.