180806-203

CourtBoard of Veterans' Appeals
DecidedSeptember 30, 2020
Docket180806-203
StatusUnpublished

This text of 180806-203 (180806-203) is published on Counsel Stack Legal Research, covering Board of Veterans' Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
180806-203, (bva 2020).

Opinion

Citation Nr: AXXXXXXXX Decision Date: 09/30/20 Archive Date: 09/30/20

DOCKET NO. 180806-203 DATE: September 30, 2020

ORDER

Service connection for lumbar spine arthritis and intervertebral disc syndrome (IVDS) with associated left lower extremity radiculopathy is granted.

Entitlement to temporary total ratings under 38 C.F.R. § 4.30 for periods of convalescence following service-connected low back surgeries on January 20, 2016 and February 16, 2017 are granted.

FINDINGS OF FACT

1. The Veteran has lumbar spine arthritis and IVDS with associated left lower extremity radiculopathy that began after a September 2006 training injury during her active military service in the U.S. Army.

2. The Veteran’s low back surgical procedures conducted on January 20, 2016 and on February 16, 2017, respectively, necessitated periods of convalescence of at least one month following each surgery.

CONCLUSIONS OF LAW

1. The criteria have been met for service connection for lumbar spine arthritis and IVDS with associated left lower extremity radiculopathy. 38 U.S.C. §§ 1101, 1110, 1112, 1113, 5107; 38 C.F.R. §§ 3.102, 3.303, 3.307, 3.309.

2. The criteria have been met for entitlement to temporary total ratings under 38 C.F.R. § 4.30 for periods of convalescence following service-connected low back surgeries on January 20, 2016 and February 16, 2017. 38 U.S.C. §§ 1155, 5107; 38 C.F.R. §§ 4.3, 4.30.

REASONS AND BASES FOR FINDINGS AND CONCLUSIONS

The Veteran had active duty service from January 1986 to January 1990 in the U.S. Air Force and from April 2005 to April 2008 in the U.S. Army.

This matter comes to the Board of Veterans’ Appeals (Board) on appeal from a June 2017, September 2017, and December 2017 rating decisions issued by an Agency of Original Jurisdiction (AOJ) of the Department of Veterans Affairs (VA). These rating decisions were issued under the previous legacy system.

However, on March 30, 2018, the Veteran opted into the modernized review system, also known as the Appeals Modernization Act (AMA), by submitting a Rapid Appeals Modernization Program (RAMP) opt-in election form. See 38 C.F.R. § 3.2400(c)(1) (2019). On this form, he selected the higher-level review (HLR) lane.

The AOJ followed up by issuing a July 2018 RAMP / HLR rating decision. Thereafter, the Veteran appealed to the Board by filing an August 2018 RAMP Selection Form, in which he selected the Hearing Lane. See 38 C.F.R. §§ 20.300, 20.302 (2019). Since the Hearing Lane has been selected, the Board may only consider the evidence of record at the time of the March 30, 2018 RAMP opt-in election form; evidence submitted by the Veteran or her representative at the August 2019 hearing; and finally, any evidence submitted by the Veteran or her representative within 90 days following the August 2019 hearing. 38 C.F.R. § 20.302(a). In fact, on the day of the August 22, 2019 hearing, the Veteran submitted two buddy statements from fellow service members within the 90 day evidentiary window discussed above. See 38 C.F.R. § 20.302(a)(3). As such, these buddy statements are timely and can be considered by the Board.

As mentioned above, in August 2019, the Veteran and her spouse presented testimony at a Board videoconference hearing before the undersigned Acting Veterans Law Judge (AVLJ). A transcript of that hearing is associated with the Veteran’s claims file.

I. Service Connection for Lumbar Spine and Left LE Radiculopathy

Service connection may be granted for disability resulting from disease or injury incurred in or aggravated by active service. 38 U.S.C. §§ 1110, 1131, 5107; 38 C.F.R. § 3.303. The three-element test for service connection requires evidence of: (1) the existence of a current disability; (2) in-service incurrence or aggravation of a disease or injury; and (3) a causal relationship between the current disability and the disease or injury incurred or aggravated during service — the “nexus” requirement. Holton v. Shinseki, 557 F.3d 1363, 1366 (Fed. Cir. 2009) (quoting Shedden v. Principi, 381 F.3d 1163, 1167 (Fed. Cir. 2004)).

VA is to give “due consideration” to “all pertinent medical and lay evidence” in evaluating a claim for disability benefits. 38 U.S.C. § 1154(a). Thus, there is no categorical rule that medical evidence is required when the determinative issue is either medical etiology or a medical nexus. Davidson v. Shinseki, 581 F.3d 1313, 1316 (Fed. Cir. 2009).

The Board should make explicit findings regarding the competency and, if necessary, the credibility of the lay evidence of record. Miller v Wilkie, 32 Vet. App. 249, 257-262 (2020). Lay testimony is competent to describe the presence of readily observable features or symptoms of injury or illness that are not medical in nature, such as varicose veins, tinnitus, and flat feet. See 38 C.F.R. § 3.159(a)(2); Barr v. Nicholson, 21 Vet. App. 303, 307-310 (2007). The Federal Circuit has also clarified that lay evidence can be competent for the diagnosis or etiology of a condition if: (1) the layperson is competent to identify the medical condition, (2) the layperson is reporting a contemporaneous medical diagnosis, or (3) lay testimony describing symptoms at the time supports a later diagnosis by a medical professional. Jandreau v. Nicholson, 492 F.3d 1372, 1376-77 (Fed. Cir. 2007). And if the disability is of the type for which lay evidence is competent, the Board must weigh the probative value of that lay evidence against other evidence of record in making its determination regarding the award of service connection. Buchanan v. Nicholson, 451 F.3d 1331, 1334-37 (Fed. Cir. 2006).

In determining whether service connection is warranted, the Board shall consider the benefit-of-the-doubt doctrine. 38 U.S.C. § 5107(b); 38 C.F.R. § 3.102; Alemany v. Brown, 9 Vet. App. 518 (1996); Gilbert v. Derwinski, 1 Vet. App. 49 (1991).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Davidson v. SHINSEKI
581 F.3d 1313 (Federal Circuit, 2009)
Jandreau v. Nicholson
492 F.3d 1372 (Federal Circuit, 2007)
Prejean v. West
13 Vet. App. 444 (Veterans Claims, 2000)
James P. Barr v. R. James Nicholson
21 Vet. App. 303 (Veterans Claims, 2007)
Angel S. Nieves-Rodriguez v. James B. Peake
22 Vet. App. 295 (Veterans Claims, 2008)
William N. Clemons v. Eric K. Shinseki
23 Vet. App. 1 (Veterans Claims, 2009)
Walker v. Shinseki
708 F.3d 1331 (Federal Circuit, 2013)
Gilbert v. Derwinski
1 Vet. App. 49 (Veterans Claims, 1990)
Guerrieri v. Brown
4 Vet. App. 467 (Veterans Claims, 1993)
Sklar v. Brown
5 Vet. App. 140 (Veterans Claims, 1993)
Kellar v. Brown
6 Vet. App. 157 (Veterans Claims, 1994)
Owens v. Brown
7 Vet. App. 429 (Veterans Claims, 1995)
Seals v. Brown
8 Vet. App. 291 (Veterans Claims, 1995)
Alemany v. Brown
9 Vet. App. 518 (Veterans Claims, 1996)
Hernandez-Toyens v. West
11 Vet. App. 379 (Veterans Claims, 1998)
Felden v. West
11 Vet. App. 427 (Veterans Claims, 1998)

Cite This Page — Counsel Stack

Bluebook (online)
180806-203, Counsel Stack Legal Research, https://law.counselstack.com/opinion/180806-203-bva-2020.