Law School Case Brief
Johnson v. Robison - 415 U.S. 361, 94 S. Ct. 1160 (1974)
Decisions of the Administrator on any question of law or fact under any law administered by the Veterans' Administration providing benefits for veterans shall be final and conclusive and no court of the United States shall have power or jurisdiction to review any such decision. The prohibitions would appear to be aimed at review only of those decisions of law or fact that arise in the administration by the Veterans' Administration of a statute providing benefits for veterans. A constitutional challenge is not to any such decision of the Administrator, but rather to a decision of Congress. Thus, questions of law presented in such proceedings arise under the Constitution, not under the statute whose validity is challenged.
A conscientious objector, who had satisfactorily completed two years of alternative civilian service, and who had thereafter been denied educational benefits under the Veterans' Readjustment Benefits Act of 1966, instituted a class action against the Veterans' Administration and the Administrator of Veterans Affairs in the United States District Court for the District of Massachusetts, seeking a declaratory judgment that the statutory scheme's restriction of educational benefits to veterans who had served on active duty violated the guarantee of religious freedom and equal protection principles as encompassed under the due process clause under the Fifth Amendement. The defendants moved to dismiss the action on the ground that the District Court lacked jurisdiction. Denying the motion to dismiss, the District Court held that although the statutory scheme did not violate First Amendment rights, it was unconstitutional as violative of Fifth Amendment equal protection.
Is the Act’s denial of educational benefits to conscientious objectors who performed required alternative civilian service violative of religious freedom and equal protection?
According to the Court, the denial of educational benefits under the Act to conscientious objectors who performed required alternative civilian service did not violate such conscientious objectors' First Amendment rights of free exercise of religion, since the withholding of educational benefits involved, at the most, only an incidental burden on free exercise of religion by conscientious objectors. Furthermore, the Act was enacted pursuant to Congress' constitutional powers to advance the neutral, secular governmental interest of enhancing military service and aiding the readjustment to civilian life of active duty veterans, and conscientious objectors who performed alternative civilian service were excluded not because of any legislative intent to interfere with their free exercise of religion, but because inclusion of such conscientious objectors would not rationally promote the Act's purposes. The Court further opined that the Act's denial of educational benefits to conscientious objectors who performed required alternative civilian service did not create an arbitrary classification in violation of such conscientious objectors' right to equal protection of the laws under the Fifth Amendment, since the disruption to one's life caused by active military service was quantitatively and qualitatively greater than that caused by a conscientious objector's alternative civilian service, such distinctions forming a rational basis for limiting educational benefits to active service veterans as a means of helping them readjust to civilian life. The Court also held that the statutory classification bore a rational relationship to the Act's purpose of making service in the armed forces more attractive.
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