In the case of Jesse Brown, Secretary of Veterans Affairs v. Fred P. Gardner (1994), the U.S Supreme Court ruled in favor of Gardner, a veteran who had been denied disability benefits by the Department of Veterans Affairs (VA). The VA argued that it was not responsible for injuries sustained during off-duty recreational activities while on active duty. However, Gardner contended that his injury occurred within an "active service" context as he was injured while playing softball at a base-sanctioned event during his military service period. The court held that under federal law 38 USC Section 101(24), any injury incurred or aggravated during active military service should be considered to have been incurred in line-of-duty and thus eligible for compensation unless there is clear evidence to prove otherwise such as misconduct leading to self-inflicted wounds or abuse of alcohol/drugs etc., which were not applicable here. This ruling set a precedent emphasizing broad interpretation when considering what constitutes 'service-connected' injuries for veterans seeking disability benefits from VA.

In the dissenting opinion for Jesse Brown, Secretary of Veterans Affairs v. Fred P. Gardner, Justice Clarence Thomas disagreed with the majority's interpretation of a federal statute that precludes judicial review of decisions made by the Department of Veterans Affairs (VA). The case involved a veteran who was denied disability benefits and sought to challenge this decision in court. The majority ruled that while most VA decisions are not subject to judicial review, those involving constitutional questions can be reviewed by courts. However, Justice Thomas argued that Congress intended for all VA decisions to be final and unreviewable - including those raising constitutional issues - as part of an effort to ensure swift resolution for veterans' claims without getting bogged down in lengthy litigation processes.