190418-17888

CourtBoard of Veterans' Appeals
DecidedApril 30, 2021
Docket190418-17888
StatusUnpublished

This text of 190418-17888 (190418-17888) 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
190418-17888, (bva 2021).

Opinion

Citation Nr: AXXXXXXXX Decision Date: 04/30/21 Archive Date: 04/30/21

DOCKET NO. 190418-17888 DATE: April 30, 2021

ORDER

Entitlement to a total disability rating based on individual unemployability (TDIU) is granted.

FINDING OF FACT

The evidence is at least in relative equipoise as to whether the Veteran’s service-connected disabilities render him unable to maintain substantially gainful employment.

CONCLUSION OF LAW

The criteria for entitlement to a TDIU have been satisfied. 38 U.S.C. §§ 1155, 5107; 38 C.F.R. §§ 3.340, 3.341, 4.16.

REASONS AND BASES FOR FINDING AND CONCLUSION

The Veteran served on active duty in the United States Air Force from July 1974 to June 1980.

This matter is on appeal to the Board of Veterans’ Appeals (Board) from a March 2019 rating decision issued by a Department of Veterans Affairs (VA) Regional Office (RO).

Procedurally, the Veteran’s case was initially in the Legacy system and in an April 2017 Board remand, the issue of entitlement to a TDIU was remanded to the Agency of Original Jurisdiction (AOJ) for additional development. Thereafter, in June 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) election form and selecting the higher-level review (HLR) lane. In October 2018 correspondence, the AOJ notified the Veteran of the discovery of a duty to assist error and forwarded the claim for further development such as gathering additional evidence, which included Social Security Administration (SSA) medical records. As noted above, a March 2019 rating decision denied entitlement to a TDIU. The RO noted that because of the duty to assist errors and subsequent development, the Veteran’s claim was decided in the supplemental claim lane.

In the April 2019 VA Form 10182, Decision Review Request: Board Appeal (Notice of Disagreement), the Veteran timely appealed the portion of the rating decision pertaining to the issue above and requested a hearing before the Board and an opportunity to submit evidence at the hearing and within 90 days following the hearing. 38 C.F.R. § 20.202. In January 2021, the Veteran testified at a hearing before a Veterans Law Judge. A transcript of that hearing is of record.

Evidence was added to the claims file during a period of time when new evidence was not allowed and the Board may not consider this evidence in its decision. 38 C.F.R. § 20.300. The Veteran may file a Supplemental Claim and submit or identify this evidence. 38 C.F.R. § 3.2501. If the evidence is new and relevant, VA will issue another decision on the claim, considering the new evidence in addition to the evidence previously considered. Id. Specific instructions for filing a Supplemental Claim are included with this decision.

TDIU

The Veteran asserts that he is unable to secure and follow a substantially gainful occupation as a result of his service-connected disabilities.

VA will grant a total rating for compensation purposes based on unemployability when the evidence shows a veteran is precluded from obtaining or maintaining any gainful employment consistent with his education and occupational experience, by reason of his service-connected disabilities. 38 C.F.R. §§ 3.340, 3.341, 4.16. In reaching such a determination, the central inquiry is “whether the Veteran’s service-connected disabilities alone are of sufficient severity to produce unemployability.” Hatlestad v. Brown, 5 Vet. App. 524, 529 (1993). In arriving at a conclusion, consideration may be given to the veteran’s level of education, special training, and previous work experience, but not to his age or the impairment caused by nonservice-connected disabilities. See 38 C.F.R. §§ 3.341, 4.16, 4.19.

The United States Court of Appeals for Veterans Claims (Court) has held that the term “unable to secure and follow a substantially gainful occupation” in 38 C.F.R. § 4.16 has two components. First, there is an economic component which essentially contemplates an occupation earning more than marginal income (outside of a protected environment) as determined by the U.S. Department of Commerce as the poverty threshold for one person. Second, there is a non-economic component dealing with the individual veteran’s ability to “follow and secure” employment. For the second component, attention must be given to: (a) the veteran’s history, education, skill and training, (b) the veteran’s physical ability (both exertional and non-exertional) to perform the type of activities (e.g., sedentary, light, medium, heavy or very heavy) required by the occupation at issue, with relevant factors such as lifting, bending, sitting, standing, walking, climbing, grasping, typing, reaching, auditory and visual, and (c) whether the Veteran has the mental ability to perform the type of activities required by the occupation at issue, with relevant factors such as memory, concentration, and ability to adapt to change, handle work place stress, get along with coworkers and demonstrate reliability and productivity. Ray v. Wilkie, 31 Vet. App. 58, 73 (2019). As “sedentary” is defined as “[r]equiring or marked by much sitting ” the Board finds that sedentary employment is a job where the worker primarily sits down. WEBSTER’S II NEW COLLEGE DICTIONARY 999 (1999).

If there is only one service-connected disability, it must be rated at least 60 percent disabling to qualify for TDIU benefits; if there are two or more such disabilities, there shall be at least one disability ratable at 40 percent or more, and sufficient additional disability to bring the combined rating to 70 percent or more. 38 C.F.R. § 4.16(a).

The Veteran meets the threshold schedular disability percentage requirement for a TDIU consideration as a result of his service-connected posttraumatic stress disorder (PTSD) and polysubstance disorder and depressive disorder, degenerative arthritis of the lumbar spine and spinal stenosis, left knee degenerative joint disease, right knee degenerative joint disease, left lower extremity radiculopathy of the sciatic nerve, right lower extremity radiculopathy of the sciatic nerve, and right eyebrow laceration. 38 C.F.R. § 4.16(a).

Military personnel records reflect the Veteran’s military occupation specialty (MOS)/rating was that of aircraft armament systems specialist. On his July 2013 and September 2013 application for unemployability he reported lower back and knee disabilities prevents him from following a substantially gainful occupation. On his October 2018 application, he reported lower back and depression prevents him from following a substantially gainful employment. The Veteran reported completing a high school education level and a year in college. He reported he last worked full-time in September 2005 and November 2005 as a bus operator.

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Related

Hatlestad v. Brown
5 Vet. App. 524 (Veterans Claims, 1993)

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Bluebook (online)
190418-17888, Counsel Stack Legal Research, https://law.counselstack.com/opinion/190418-17888-bva-2021.