180921-403

CourtBoard of Veterans' Appeals
DecidedNovember 15, 2018
Docket180921-403
StatusUnpublished

This text of 180921-403 (180921-403) 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
180921-403, (bva 2018).

Opinion

Citation Nr: AXXXXXXXX Decision Date: 11/15/18 Archive Date: 11/15/18

DOCKET NO. 180921-403 DATE: November 15, 2018 ORDER Service connection for residuals, head injury is denied. REMANDED Service connection for migraine headaches is remanded. FINDING OF FACT The Veteran does not have a current disability of residuals, head injury. CONCLUSION OF LAW The criteria for entitlement to service connection for residuals, head injury have not been met. 38 U.S.C. §§ 1131, 1151 (2012); 38 C.F.R. §§ 3.303, 3.304 (2017).

REASONS AND BASES FOR FINDING AND CONCLUSION The Veteran served on active duty from July 1979 to September 1982. On August 23, 2017, the President signed into law the Veterans Appeals Improvement and Modernization Act, Pub. L. No. 115-55 (to be codified as amended in scattered sections of 38 U.S.C.), 131 Stat. 1105 (2017), also known as the Appeals Modernization Act (AMA). This law creates a new framework for Veterans dissatisfied with VA’s decision on their claim to seek review. The Veteran chose to participate in VA’s test program RAMP, the Rapid Appeals Modernization Program. This decision has been written consistent with the new AMA framework. The Board of Veterans’ Appeals (Board) notes that the Veteran withdrew his hearing request in September 2018. See September 2018 VA Form 21-4138, Statement in Support of Claim. Thus, the matter is before the Board for adjudication. 1. Service connection for residuals, head injury The Veteran contends he is entitled to service connection for residuals of head injury. Service connection may be granted for any current disability that is the result of a disease contracted or an injury sustained in the line of duty during active military service. 38 U.S.C. § 1110 (2012); 38 C.F.R. § 3.303(a) (2017). Service connection may be granted for a disease diagnosed after discharge, when the evidence, including that pertinent to service, establishes the disease was incurred in service. 38 C.F.R. § 3.303(d) (2017). Establishing service connection generally requires medical or, in certain circumstances, lay evidence of (1) a current disability; (2) in-service incurrence or aggravation of a disease or injury; and (3) a link between the claimed in-service disease or injury and the present disability. Romanowsky v. Shinseki, 26 Vet. App. 289, 293 (2013). Service connection may also be established with certain chronic diseases based upon a legal presumption by showing that the disorder manifested itself to a degree of 10 percent disabling or more within one year from the date of separation from service. Such disease shall be presumed to have been incurred in service, even though there is no evidence of such disease during the period of service. 38 U.S.C. §§ 1101, 1112, 1113, 1137; 38 C.F.R. §§ 3.307, 3.309(a). While the disease need not be diagnosed within the presumption period, it must be shown, by acceptable lay or medical evidence, that there were characteristic manifestations of the disease to the required degree during that time. Lay statements may serve to support a claim for service connection by supporting the occurrence of lay-observable events or the presence of disability, or symptoms of disability, susceptible of lay observation. Davidson v. Shinseki, 581 F.3d 1313 (Fed. Cir. 2009); Jandreau v. Nicholson, 492 F.3d 1372 (Fed. Cir. 2007). When a claimant seeks benefits and the evidence for and against the claim is in relative equipoise, the claimant prevails. 38 U.S.C. § 5107; 38 C.F.R. § 3.102; Gilbert v. Derwinski, 1 Vet. App. 49 (1990). The preponderance of the evidence must be against the claim for a claim to be denied. Alemany v. Brown, 9 Vet. App. 518 (1996). Factual Background The Veteran’s service treatment records (STRs) confirm that in March 1981, the Veteran fell while riding a bike and landed on his face. He was given four stiches. See STR-Medical, March 1981 Treatment Note. The Veteran also sustained several lacerations on the back of his head due to being hit with a beer stein in June 1981. See STR-Medical, June 1981 Treatment Note. The record does not contain a separation examination and the Veteran confirmed that he was not provided such an examination. See October 2018 Correspondence. The Veteran’s post-service treatment records do not show any diagnosis of residuals of a head injury. Analysis A review of the medical evidence of record fails to establish a current disability of residuals of head injury at any time during the appeal period or proximate thereto. See McClain v. Nicholson, 21 Vet. App. 319, 321 (2007); Romanowsky v. Shinseki, 26 Vet. App. 289 (2013). Although the Veteran was treated for a head injury during service, his post-service treatment records fail to show diagnosis or treatment for residuals of head injury. The Board also notes that the Veteran is service connected for facial scars, and is seeking service connection for migraine headaches. These disabilities encompass the Veteran’s symptoms of residuals of head injury. The Board is cognizant of the recent ruling of the United States Court of Appeals for the Federal Circuit (Federal Circuit) in Saunders v. Wilkie, 886 F.3d 1356 (Fed. Cir. 2018). In that case, the Federal Circuit found that the term “disability” as used in 38 U.S.C. § 1110 “refers to the functional impairment of earning capacity, not the underlying cause of said disability,” and held that “pain alone can serve as a functional impairment and therefore qualify as a disability.” Id., at 1368. In other words, where pain alone results in functional impairment, even if there is no identified underlying diagnosis, it can constitute a disability. The Federal Circuit limited its holding, stating, “[w]e do not hold that a veteran could demonstrate service connection simply by asserting subjective pain. To establish the presence of a disability, the veteran will need to show that his pain reaches the level of functional impairment of earning capacity.” In other words, subjective pain in and of itself will not establish a current disability. Consideration should be given to the impact, or lack thereof, from pain, focusing on evidence of functional limitation caused by pain. Here, there is no indication that the Veteran experiences functional impairment as a result of residuals of head injury. In light of the lack of functional impairment or clinical diagnosis, the evidence does not support a finding of any residuals of head injury disability. In forming this opinion, the Board has also considered the Veteran’s lay statements in support of his claim. However, the Board finds the medical evidence more probative in this instance, where the Veteran has not demonstrated that he has the requisite technical background to diagnosis such a condition. Davidson v.

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Related

Davidson v. SHINSEKI
581 F.3d 1313 (Federal Circuit, 2009)
Jandreau v. Nicholson
492 F.3d 1372 (Federal Circuit, 2007)
Ray A. Mc Clain v. R. James Nicholson
21 Vet. App. 319 (Veterans Claims, 2007)
Woehlaert v. Nicholson
21 Vet. App. 456 (Veterans Claims, 2007)
Steven M. Romanowsky v. Eric K. Shinseki
26 Vet. App. 289 (Veterans Claims, 2013)
Saunders v. Wilkie
886 F.3d 1356 (Federal Circuit, 2018)
Gilbert v. Derwinski
1 Vet. App. 49 (Veterans Claims, 1990)
Brammer v. Derwinski
3 Vet. App. 223 (Veterans Claims, 1992)
Alemany v. Brown
9 Vet. App. 518 (Veterans Claims, 1996)

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180921-403, Counsel Stack Legal Research, https://law.counselstack.com/opinion/180921-403-bva-2018.