190422-8159

CourtBoard of Veterans' Appeals
DecidedMarch 31, 2020
Docket190422-8159
StatusUnpublished

This text of 190422-8159 (190422-8159) 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
190422-8159, (bva 2020).

Opinion

Citation Nr: AXXXXXXXX Decision Date: 03/31/20 Archive Date: 03/31/20

DOCKET NO. 190422-8159 DATE: March 31, 2020

ORDER

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

FINDING OF FACT

The Veteran meets the schedular criteria for TDIU from November 20, 2014; his service-connected disabilities preclude him from securing or maintaining gainful employment.

CONCLUSION OF LAW

The criteria for entitlement to a total disability rating based on individual unemployability (TDIU) have been met. 38 U.S.C. §§ 1110, 5103, 5103A, 5107; 38 C.F.R. §§ 3.102, 3.340, 3.341, 4.3, 4.15, 4.16.

REASONS AND BASES FOR FINDING AND CONCLUSION

The Veteran served as a member of the United States Army, with active duty service from June 1966 to June 1969.

This appeal comes to the Board of Veterans’ Appeals (Board) from a December 2018 rating decision by a Department of Veterans Affairs (VA) Regional Office (RO). In its decision, the RO denied entitlement to individual unemployability because the evidence did not show that he was unable to secure or follow a substantially gainful occupation as a result of his service-connected disabilities. The Veteran timely appealed.

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. In December 2018, the Veteran submitted a RAMP Opt-in Election form, selecting the Direct Review lane for his appeal.

Entitlement to a total rating based on individual unemployability (TDIU)

Disability ratings are determined by applying the criteria set forth in the VA’s Schedule for Rating Disabilities (“Rating Schedule”), which is based on the average impairment of earning capacity. 38 U.S.C. § 1155. Total disability is considered to exist when there is any impairment which is sufficient to render it impossible for the average person to follow a substantially gainful occupation. 38 C.F.R. § 3.340(a)(1). Total disability may or may not be permanent. Id. Total ratings are authorized for any impairment or combination of impairments for which the Rating Schedule prescribes a 100 percent evaluation. 38 C.F.R. § 3.340(a)(2).

A TDIU may be assigned when the disabled person is, in the judgment of the rating agency, unable to secure or follow a substantially gainful occupation as a result of their service-connected disabilities. 38 C.F.R. § 4.16(a). If there is only one such disability, it must be rated as at least 60-percent disabling, and if there are two or more disabilities, at least one disability must be rated as at least 40-percent disabling and there must be sufficient additional disability to bring the combined rating to at least 70 percent. Id.

For the above purpose of one 60 percent disability, or one 40 percent disability in combination, the following will be considered as one disability: (1) disabilities of one or both upper extremities, or of one or both lower extremities, including the bilateral factor, if applicable, (2) disabilities resulting from common etiology or a single accident, (3) disabilities affecting a single body system, e.g. orthopedic, digestive, respiratory, cardiovascular-renal, neuropsychiatric, (4) multiple injuries incurred in action, or (5) multiple disabilities incurred as a prisoner of war. Id.

Entitlement to a total rating must be based solely on the impact of the Veteran’s service-connected disabilities on his ability to keep and maintain substantially gainful employment. See 38 C.F.R. §§ 3.340, 3.341, 4.16. While the regulations do not provide a definition of “substantially gainful employment,” the VA Adjudication Procedure Manual, M21-1, Part VI, paragraph 7.09(a)(7), defines the term as “that which is ordinarily followed by the nondisabled to earn their livelihood with earnings common to the particular occupation in the community where the Veteran resides.” Also, in Faust v. West, 13 Vet. App. 342 (2000), the Court of Appeals for Veterans Claims (“Court/CAVC”) defined “substantially gainful employment” as an occupation “that provides an annual income that exceeds the poverty threshold for one person, irrespective of the number of hours or days that the Veteran actually works and without regard to the Veteran’s earned annual income.”

The ability to work sporadically or obtain marginal employment is not substantially gainful employment. 38 C.F.R. § 4.16(a); Moore v. Derwinski, 1 Vet. App. 356, 358 (1991). Marginal employment, i.e., earned annual income that does not exceed the poverty threshold for one person, is not considered substantially gainful employment. 38 C.F.R. § 4.16(a). Marginal employment also may be held to exist on a facts-found basis when earned annual income exceeds the poverty threshold. Id. Such situations may include, but are not limited to, employment in a protected environment such as a family business or sheltered workshop. Id.

Requiring a Veteran to prove that he is 100-percent, i.e., totally unemployable, is different than requiring he prove that he cannot maintain substantially gainful employment. The use of the word “substantially” suggests intent to impart flexibility into a determination of the Veteran’s overall employability, whereas a requirement that a Veteran prove 100-percent unemployability leaves no flexibility. Roberson v. Principi, 251 F.3d 1378, 1385 (Fed. Cir. 2001).

That said, as already alluded to, to receive a TDIU, the Veteran’s service-connected disabilities, alone, must be sufficiently severe to cause unemployability. Hatlestad v. Brown, 5 Vet. App. 524, 529 (1993). Furthermore, VA regulations provide that all Veterans who, in light of their individual circumstance, but without regard to age, are unable to secure and follow a substantially gainful occupation as a result of service-connected disability shall be rated totally disabled, without regard to whether an average person would be rendered unemployable under the circumstances. See VAOPGPREC 75-91; 57 Fed. Reg. 2317 (1992).

Consideration may be given to the Veteran’s level of education, special training, and previous work experience in arriving at a conclusion. 38 C.F.R. § 4.16(b). However, individual unemployability must be determined without regard to any nonservice-connected disabilities or the Veteran’s advancing age. 38 C.F.R. §§ 3.341(a), 4.16, 4.19; Van Hoose v. Brown, 4 Vet. App. 361 (1993).

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Related

Faust v. West
13 Vet. App. 342 (Veterans Claims, 2000)
Geib v. Shinseki
733 F.3d 1350 (Federal Circuit, 2013)
Jimmy H. Floore v. Eric K. Shinseki
26 Vet. App. 376 (Veterans Claims, 2013)
Hatlestad v. Derwinski
1 Vet. App. 164 (Veterans Claims, 1991)
Moore v. Derwinski
1 Vet. App. 356 (Veterans Claims, 1991)
Simon v. Derwinski
2 Vet. App. 621 (Veterans Claims, 1992)
Abernathy v. Principi
3 Vet. App. 461 (Veterans Claims, 1992)
Van Hoose v. Brown
4 Vet. App. 361 (Veterans Claims, 1993)
Blackburn v. Brown
4 Vet. App. 395 (Veterans Claims, 1993)
Hodges v. Brown
5 Vet. App. 375 (Veterans Claims, 1993)
Hatlestad v. Brown
5 Vet. App. 524 (Veterans Claims, 1993)
Gabrielson v. Brown
7 Vet. App. 36 (Veterans Claims, 1994)
Caluza v. Brown
7 Vet. App. 498 (Veterans Claims, 1995)
Struck v. Brown
9 Vet. App. 145 (Veterans Claims, 1996)

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190422-8159, Counsel Stack Legal Research, https://law.counselstack.com/opinion/190422-8159-bva-2020.