190211-3649

CourtBoard of Veterans' Appeals
DecidedJune 25, 2019
Docket190211-3649
StatusUnpublished

This text of 190211-3649 (190211-3649) 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
190211-3649, (bva 2019).

Opinion

Citation Nr: AXXXXXXXX Decision Date: 06/25/19 Archive Date: 06/24/19

DOCKET NO. 190211-3649 DATE: June 25, 2019

ISSUES

Whether there was clear and unmistakable error (CUE) in a December 2013 rating decision that denied entitlement to service connection for a lumbar back disability, a right knee disability, a left hand disability, and a right hand disability.

Entitlement to service connection for a lumbar back disability.

Entitlement to service connection for a right knee disability.

Entitlement to service connection for a left hand disability.

Entitlement to service connection for a right hand disability.

Entitlement to service connection for a left wrist disability.

Entitlement to service connection for a right wrist disability.

ORDER

Clear and unmistakable error (CUE) was not found in a December 2013 decision that denied entitlement to service connection for a lumbar back disability, a right knee disability, a left hand disability, and a right hand disability.

REMANDED

Entitlement to service connection for a lumbar back disability is remanded.

Entitlement to service connection for a right knee disability is remanded.

Entitlement to service connection for a left hand disability is remanded.

Entitlement to service connection for a right hand disability is remanded.

Entitlement to service connection for a left wrist disability is remanded.

Entitlement to service connection for a right wrist disability is remanded.

FINDING OF FACT

The December 2013 rating decision that denied entitlement to service connection for a lumbar back disability, a right knee disability, a left hand disability, and a right hand disability was reasonably supported by the evidence of record at that time, was consistent with the laws and regulations then in effect, and it did not contain undebatable error that would have manifestly changed the outcome.

CONCLUSION OF LAW

The December 2013 rating decision did not contain clear and unmistakable error. 38 U.S.C. § 5109A (2012); 38 C.F.R. § 3.105(a) (2018).

REASONS AND BASES FOR FINDING AND CONCLUSION

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 Veteran served on active duty from February 1993 to March 2013.

This case has a complex procedural history. By way of background, the VA regional office (RO) denied claims of entitlement to service connection for a lumbar back disability, a right knee disability, a left hand disability, and a right hand disability in December 2013. The Veteran and his representative were notified of that decision, but did not file a notice of disagreement, and thus that decision became final.

In August 2016, the Veteran filed a claim to reopen his four claims for service connection that were denied in December 2013, and added two additional claims: service connection each for the left wrist and the right wrist. A December 2016 rating decision denied reopening of the claims of service connection for a lumbar back disability, a right knee disability, a left hand disability, and a right hand disability. A subsequent rating decision in February 2017 denied the claims for service connection for the left wrist and the right wrist on the merits.

In February 2017, the Veteran filed a claim asserting CUE in the December 2016 rating decision that denied a lumbar back disability, a right knee disability, a left hand disability, and a right hand disability. In August 2017, the RO adjudicated and denied the Veteran’s February 2017 CUE claim, and also denied the service connection claims on the merits. The Veteran filed another claim for the same six issues in April 2018, and was again denied in May 2018.

Following that, in August 2018, the Veteran filed another notice of disagreement, and in November 2018, submitted the RAMP election form while selecting the Supplemental Claim lane. 84 Fed. Reg. 138, 177 (Jan. 18, 2019) (to be codified at 38 C.F.R. § 19.2(d)). The RO adjudicated all six issues for service connection in a January 2019 rating decision, which considered the evidence of record prior to the issuance of the RAMP rating decision. The Veteran then made a timely appeal of that RAMP decision to the Board and requested Direct Review of the evidence considered by the Agency of Original Jurisdiction (AOJ).

In the January 2019 RAMP decision, the AOJ determined that new and relevant evidence was received to warrant readjudicating the claims for service connection for a lumbar back disability, a right knee disability, a left hand disability, and a right hand disability. The Board is bound by this favorable finding. 84 Fed. Reg. 138, 167 (Jan. 18, 2019) (to be codified at 38 C.F.R. § 3.104(c)). As such, the Board need not adjudicate the reopening of the claim again and may proceed to the merits of all six of the service connection claims. The CUE claim will be considered separately, as the law and regulations for CUE were not altered in the 2017 AMA.

Clear and Unmistakable Error (CUE)

Veterans Claims Assistance Act of 2000 (VCAA): Duties to Assist and Notify

With regard to the Veteran’s CUE claim, the United States Court of Appeals for Veterans Claims (Court or CAVC) has specifically held that the VCAA has no application to allegations of CUE as a matter of law, regardless of whether the Board or RO issued the earlier decision in question. The VCAA does not apply to CUE claims or motions because they are not claims for benefits, but, rather, are a collateral attack on a final decision. See Livesay v. Principi, 15 Vet. App. 165, 178-79 (2001) (en banc); Parker v. Principi, 15 Vet. App. 407 (2002); see also 38 U.S.C. §§ 5109A (a); 7111(a); 38 C.F.R. §§ 20.1400-20.1411.

Legal Basis for CUE

Generally, CUE must be pled with some degree of specificity as to what the alleged error is and, unless it is the kind of error that if true would be CUE on its face, the claimant must also give persuasive reasons as to why the result of the prior determination would have been manifestly different but for the alleged error. Fugo v. Brown, 6 Vet. App. 40, 44 (1993); see also Phillips v. Brown, 10 Vet. App. 25 (1997).

Previous determinations that are final and binding (including decisions of service connection, degree of disability, age, marriage, relationship, service, dependency, line of duty, and other issues) will be accepted as correct in the absence of CUE. Where evidence establishes such error, the prior decision will be reversed or amended. 38 U.S.C. §§ 5109A, 7105(c), 7111(a) (2012); 38 C.F.R. §§ 3.104

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Related

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9 Vet. App. 52 (Veterans Claims, 1996)
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Phillips v. Brown
10 Vet. App. 25 (Veterans Claims, 1997)
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Livesay v. Principi
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190211-3649, Counsel Stack Legal Research, https://law.counselstack.com/opinion/190211-3649-bva-2019.