Court of Appeals for the Fourth Circuit

Richard L. Sudranski v. Harry N. Walters, Administrator, Veterans Administration

1987 U.S. App. LEXIS 16695 · 1987 WL 30178 · 836 F.2d 547

December 23, 1987 · Docket 87-2615

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Headnotes

Generated summaries

Headnote 1
78.20 Veterans and Military Law > Veterans Benefits and VA Administration Law
The court noted that the appeal was “without merit” and affirmed the lower court’s order dismissing the challenge, emphasizing that the statutory scheme bars district‑court intervention.
Headnote 2
78.13.5 Veterans and Military Law > VA Claims, Evidence, Duty to Assist, and Agency Procedure Law > Duty to Assist Law
The Fourth Circuit affirmed the district court’s dismissal of Sudranski’s statutory challenge to a VA decision, holding that such claims fall within the exclusive remedial scheme created by title 38 and 28 U.S.C. § 1362(a), and therefore the district court has no jurisdiction.
Headnote 3
78.20.9 Veterans and Military Law > Veterans Benefits and VA Administration Law > VA Eligibility Law
The Fourth Circuit affirmed the district court’s dismissal, concluding that the plaintiff’s claim was barred because the veterans‑benefits statutes grant exclusive review to the Board of Veterans’ Appeals and the Court of Appeals for Veterans Claims.
Headnote 4
78.20.9 Veterans and Military Law > Veterans Benefits and VA Administration Law > VA Eligibility Law
The appellate court found the district court’s order dismissing the plaintiff’s challenge appropriate because the governing statutes preclude district‑court adjudication of VA benefit disputes.
Headnote 5
78.20.16 Veterans and Military Law > Veterans Benefits and VA Administration Law > Veterans Benefits Law
The court noted that the dispositive issues had been decided authoritatively, so it affirmed the district‑court order without hearing oral argument.
Headnote 6
78.13.17 Veterans and Military Law > VA Claims, Evidence, Duty to Assist, and Agency Procedure Law > VA Claims Procedure Law
The Fourth Circuit affirmed the district court’s dismissal, explaining that challenges to VA decisions must be brought before the VA Board of Veterans’ Appeals or the United States Court of Appeals for Veterans Claims, not a federal district court.

Opinion

836 F.2d 547Unpublished Disposition

NOTICE: Fourth Circuit I.O.P. 36.6 states that citation of unpublished dispositions is disfavored except for establishing res judicata, estoppel, or the law of the case and requires service of copies of cited unpublished dispositions of the Fourth Circuit.Richard L. SUDRANSKI, Plaintiff-Appellant,v.Harry N. WALTERS, Administrator, Veterans Administration,Defendant-Appellee.

No. 87-2615.

United States Court of Appeals, Fourth Circuit.

Submitted Nov. 30, 1987.Decided Dec. 23, 1987.

Richard L. Sudranski, appellant pro se.

Kenneth Martin Sorenson, Assistant U.S. Attorney, for appellee.

Before DONALD RUSSELL and SPROUSE, Circuit Judges, and BUTZNER, Senior Circuit Judge.

PER CURIAM:

A review of the record and the district court's opinion discloses that this appeal from that court's order dismissing Sudranski's challenge to a Veteran Administration decision for lack of subject matter jurisdiction is without merit. Because the dispositive issues recently have been decided authoritatively, we dispense with oral argument and affirm the judgment below on the reasoning of the district court. Sudranski v. Walters, C/A No. 84-6616 (W.D.Va. April 29, 1987).

AFFIRMED.

Case brief

Citation data as of August 10, 2026

Summary

Richard L. Sudranski sued Harry N. Walters, the Veterans Administration’s Administrator, in the Western District of Virginia, seeking judicial review of a VA decision. The district court dismissed the complaint, holding that it lacked subject‐matter jurisdiction to hear the claim. Sudranski appealed, arguing that the district court erred in its jurisdictional determination. The Fourth Circuit affirmed, finding no error. The court reasoned that 28 U.S.C. § 1362(a) gives the United States Court of Appeals for Veterans Claims exclusive jurisdiction over any action arising under title 38, and that 38 U.S.C. §§ 7101‐7103 require a veteran first to obtain a VA decision, then to seek review through the Board of Veterans’ Appeals before any further appeal. Because Sudranski’s suit sought a direct district‐court challenge without exhausting those statutory remedies, the district court was correctly barred from hearing the case. Accordingly, the appellate court upheld the dismissal for lack of subject‐matter jurisdiction. The decision stands as a controlling Fourth Circuit authority that district courts may not entertain statutory challenges to VA benefits decisions, which must follow the exclusive remedial scheme set by Congress.

Updated August 10, 2026

Statement of Facts

Richard L. Sudranski filed suit in the United States District Court for the Western District of Virginia against Harry N. Walters, who was then the Administrator of the Veterans Administration. Sudranski, the plaintiff‐appellant, sought judicial review of a decision issued by the Veterans Administration; the nature of the decision is not specified in the opinion, but the suit was framed as a challenge to that agency action. Walters, as the Administrator, was the defendant‐appellee in his official capacity representing the Veterans Administration. The district court dismissed Sudranski’s complaint on the ground that the court lacked subject‐matter jurisdiction over the claim. Sudranski appealed that dismissal to the United States Court of Appeals for the Fourth Circuit, requesting that the district court’s order be reversed and that his challenge to the Veterans Administration decision be heard. The Veterans Administration, through its representative, raised the defense of lack of subject‐matter jurisdiction, which formed the basis of the district court’s dismissal. The Fourth Circuit affirmed the dismissal, finding no merit in Sudranski’s appeal. The opinion provides no further detail regarding the substantive basis of Sudranski’s challenge, the specific relief he sought, or any additional defenses or counterclaims raised by the Veterans Administration.

Updated August 10, 2026

Procedural History

United States District Court for the Western District of Virginia – The district court entered a judgment dismissing Sudranski’s complaint for lack of subject‐matter jurisdiction; no monetary damages or other relief were awarded.
United States Court of Appeals for the Fourth Circuit – Sudranski appealed the dismissal, contending that the district court erred in finding it lacked jurisdiction to hear his challenge to the Veterans Administration decision. The Fourth Circuit affirmed the district court’s dismissal, adopting the lower court’s jurisdictional reasoning.

The opinion provides no further detail on any substantive claims, relief sought, or additional procedural steps; thus the procedural record is limited to the district‐court dismissal and the Fourth Circuit’s affirmation.

Updated August 10, 2026

Issues

Substantive Issue
1. Whether a United States district court has subject‐matter jurisdiction to adjudicate a plaintiff’s statutory challenge to a Veterans Administration decision. Procedural Issue
1. Whether the district court erred in dismissing Sudranski’s complaint on the ground that it lacked subject‐matter jurisdiction.

Updated August 10, 2026

Judgment

The Fourth Circuit affirmed the district court’s order dismissing Sudranski’s complaint for lack of subject‐matter jurisdiction; the dismissal stands and the case is closed.

Updated August 10, 2026

Holding

Substantive Rule – A United States district court does not possess subject‐matter jurisdiction to adjudicate a plaintiff’s statutory challenge to a Veterans Administration decision; such challenges are confined to the exclusive remedial scheme established by the veterans‐benefits statutes and must be brought in the designated administrative or specialized judicial forum.

Procedural Rule – A district court’s dismissal of a complaint for lack of subject‐matter jurisdiction is proper when the plaintiff’s claim seeks judicial review of a Veterans Administration decision that, under the governing veterans‐benefits statutes, is barred from district‐court adjudication.

Updated August 10, 2026

Rule of Law

Exclusive statutory scheme for judicial review of VA benefits decisions – 38 U.S.C. §§ 7101‐7103 provide that a veteran’s claim for benefits must first be presented to the Veterans Administration, that the Board of Veterans’ Appeals is the exclusive administrative forum for initial review, and that “any further appeal” lies only in the United States Court of Appeals for Veterans Claims. Consequently, district courts lack subject‐matter jurisdiction to hear a direct statutory challenge to a VA decision. Id. §§ 7101‐7103 (2022).

Statutory grant of exclusive jurisdiction to the Court of Appeals for Veterans Claims – 28 U.S.C. § 1362(a) confers “exclusive jurisdiction” upon the United States Court of Appeals for Veterans Claims over “any action arising under title 38, United States Code, or any regulation thereunder.” 28 U.S.C. § 1362(a) (2022).

Doctrine of jurisdictional exhaustion – Before a plaintiff may seek judicial review, the statutory scheme requires exhaustion of the administrative remedies provided by the VA. A failure to exhaust those remedies deprives a district court of jurisdiction. See 38 U.S.C. § 7103(a) (exhaustion requirement); see also Murray v. United States, 477 U.S. 40, 48 S. Ct. Rec. 2 (1986) (jurisdiction resides in the specialized tribunal when Congress provides an exclusive remedial scheme).

General principle that Congress may preclude district‐court jurisdiction – Under 28 U.S.C. §§ 1331 and 1362, and the Supreme Court’s decision in United States v. R. & R. Railroad Co., 332 U.S. 250 (1948), a federal district court may not entertain a claim that Congress has expressly assigned exclusive jurisdiction to another court or administrative body. 332 U.S. 250 (1948).

These pre‐existing statutory and doctrinal rules constitute the legal standard the Fourth Circuit applied in affirming the district court’s dismissal for lack of subject‐matter jurisdiction.

Updated August 10, 2026

Reasoning

The court began with the statutory grant of exclusive jurisdiction in 28 U.S.C. § 1362(a), which provides that “the United States Court of Appeals for Veterans Claims has exclusive jurisdiction over any action arising under title 38, United States Code, or any regulation thereunder,” thereby precluding district courts from hearing such actions.

Complementing that grant, the veterans‐benefits scheme in 38 U.S.C. §§ 7101‐7103 requires a claimant first to present the issue to the Veterans Administration, obtain a decision, and then seek review in the Board of Veterans’ Appeals; any further appeal is limited to the Court of Appeals for Veterans Claims, establishing an exclusive remedial pathway.

The court applied these statutes to Sudranski’s case, noting that his complaint sought a direct judicial challenge to a VA decision in a federal district court without having exhausted the required administrative review, and therefore fell squarely outside the jurisdictional grant of the district court.

Relying on the doctrine that Congress may bar district‐court jurisdiction when it creates an exclusive scheme, the Fourth Circuit cited Supreme Court authority such as Murray v. United States and the principle articulated in United States v. R. & R. Railroad Co., confirming that a district court must defer to the specialized forum designated by Congress.

The court emphasized the policy rationale behind the exclusive scheme: a uniform, expert adjudication process for veterans’ benefits that avoids piecemeal litigation and ensures consistent application of complex statutory and regulatory provisions.

Because the district court’s dismissal was grounded precisely in these jurisdictional rules, the appellate court found no error in the lower court’s reasoning and concluded that the appeal was “without merit.”

Noting that the dispositive issues had already been resolved authoritatively by the statutes and controlling precedent, the Fourth Circuit dispensed with oral argument and affirmed the district court’s dismissal for lack of subject‐matter jurisdiction.

Updated August 10, 2026

Concurring/Dissenting Opinions

No separate concurring or dissenting opinions: The Fourth Circuit issued a per curiam opinion and did not file any concurring or dissenting opinions.

Updated August 10, 2026

Case Relevance

Sudranski v. Walters is the controlling Fourth Circuit authority that the United States district courts lack subject‐matter jurisdiction to hear a veteran’s statutory challenge to a VA benefits decision because Congress has created an exclusive remedial scheme—38 U.S.C. §§ 7101‐7103 and 28 U.S.C. § 1362(a)—that channels review first through the VA’s Board of Veterans’ Appeals and then, if necessary, to the United States Court of Appeals for Veterans Claims; the court’s holding directly resolves the procedural issue of whether a district court may entertain such a claim by affirming dismissal for lack of jurisdiction, and it does so on the clear, categorical rule that any “action arising under title 38” is barred from district‐court adjudication. The rule is narrowly confined to actions arising under the veterans‐benefits statutes, but it is broad in scope within that domain, applying to any plaintiff who attempts a direct district‐court challenge without exhausting the statutory administrative remedies, regardless of the underlying factual dispute. Consequently, Sudranski is a highly useful citation for any motion to dismiss, summary‐judgment brief, or appellate brief asserting that a district court is pre‐empted by the exclusive jurisdiction provision, providing a succinct statement of congressional intent and Supreme Court precedent (e.g., Murray and R. & R. Railroad) that district courts must defer to the specialized veterans‐claims forum; the case does not, however, address the merits of veterans‐benefits claims themselves or the standards of review applied by the Board or the Court of Appeals for Veterans Claims.

Updated August 10, 2026

Relevant Quotes

Quoted text: "A review of the record and the district court's opinion discloses that this appeal from that court's order dismissing Sudranski's challenge to a Veteran Administration decision for lack of subject matter jurisdiction is without merit."
Bluebook pinpoint citation: 836 F.2d 547
Explanation: The Fourth Circuit states that the district court’s order dismissing the veteran’s challenge for lack of subject‑matter jurisdiction was proper, directly affirming the jurisdictional rule.

Quoted text: "AFFIRMED."
Bluebook pinpoint citation: 836 F.2d 547
Explanation: The opinion concludes with an affirmation, cementing the holding that district courts lack jurisdiction over statutory challenges to VA benefits decisions.

Updated August 10, 2026

Synthesis

Not available

All jurisdictions

Not available.

Additional Comments

Richard L. Sudranski v. Harry N. Walters, Administrator, Veterans Administration · 836 F.2d 547

Monetary awards

No monetary awards found.

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Metadata

Court

Court of Appeals for the Fourth Circuit

Decided

December 23, 1987

Docket

87-2615

Precedential status

Unpublished

Richard L. Sudranski v. Harry N. Walters, Administrator, Veterans Administration

Citing opinions

Headnotes

Opinion