190531-99372

CourtBoard of Veterans' Appeals
DecidedNovember 30, 2020
Docket190531-99372
StatusUnpublished

This text of 190531-99372 (190531-99372) 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
190531-99372, (bva 2020).

Opinion

Citation Nr: AXXXXXXXX Decision Date: 11/30/20 Archive Date: 11/30/20

DOCKET NO. 190531-99372 DATE: November 30, 2020

ORDER

Entitlement to additional attorney fees based on the total amount of past-due benefits awarded in the December 2018 rating decision and January 2019 dependency decision, prior to withholding for military retired pay, is granted.

FINDING OF FACT

The appellant is entitled to attorney fees based on the total award of past-due benefits granted in the December 2018 rating decision and January 2019 dependency decision, prior to withholding for military retired pay.

CONCLUSION OF LAW

The criteria for additional attorney fees to the appellant based on the of past-due benefits awarded in the December 2018 rating decision and January 2019 dependency decision, prior to withholding for military retired pay, are met. 38 U.S.C. § 5904; 38 C.F.R. § 14.636.

REASONS AND BASES FOR FINDING AND CONCLUSION

The Veteran served on active duty from May 1975 to May 1990. The appellant is the Veteran’s attorney representative.

This matter is before the Board of Veterans’ Appeals (Board) on appeal from a March 2019 decision of a Department of Veterans Affairs (VA) Regional Office (RO) which granted attorney fees based on past-due benefits awarded in a January 2019 rating decision.

In May 2019, the appellant submitted a VA Form 10182, Decision Review Request: Board Appeal (Notice of Disagreement) and requested Direct Review by a Veterans Law Judge. The Board notes that in April 2019, the appellant filed a Higher Level Review Request. In a May 2019 letter, the RO informed the appellant that this was the incorrect venue for this type of appeal, and the March 2019 letter contained the incorrect appeal form. The RO sent the appellant the correct form, a VA Form 10182, and the appellant submitted the Decision Review Request within 60 days of the May 2019 letter. Therefore, the appeal is timely. As the appellant selected Direct Review, the Board may only consider the evidence of record at the time of the agency of original jurisdiction (AOJ) decision on appeal. 38 C.F.R. § 20.301.

A claimant may have attorney or agent representation for the prosecution of claims for VA benefits. 38 U.S.C. § 5904.

When an AOJ has issued a notice of an initial decision on or after the effective date of the modernized review system, February 19, 2019, agents and attorneys may charge claimants or appellants for representation provided if the notice of the initial decision was issued on or after the effective date of the modernized review system, and the agent or attorney has complied with the power of attorney requirements in 38 C.F.R. § 14.631 and the fee agreement requirements in 38 C.F.R. § 14.636(g). An initial decision on a claim would include an initial decision on an initial claim for an increase in rate of benefit, an initial decision on a request to revise a prior decision based on clear and unmistakable error (CUE), and an initial decision on a supplemental claim that was presented after the final adjudication of an earlier claim.

For initial decisions issued prior to February 19, 2019, agents and attorneys may charge claimants or appellants for representation provided: After an AOJ has issued a decision on a claim or claims, including any claim to reopen under 38 C.F.R. § 3.156(a) or for an increase in rate of a benefit; the AOJ issued notice of that decision before the effective date of the modernized review system; an NOD has been filed with respect to that decision on or after June 20, 2007; and the agent or attorney has complied with the power of attorney requirements in 38 C.F.R. § 14.631 and the fee agreement requirements in 38 C.F.R. § 14.636(g). Agents and attorneys may charge fees for representation provided with respect to a request for revision of a decision of an AOJ or the Board based on CUE if notice of the challenged decision was issued before the effective date of the modernized review system; an NOD was filed with respect to the challenged decision on or after June 20, 2007; and the agent or attorney has complied with the power of attorney requirements in 38 C.F.R. § 14.631 and the fee agreement requirements in 38 C.F.R. § 14.636(g). 38 C.F.R. § 14.636(c)(2).

When a claimant or appellant and an attorney or agent have entered into a fee agreement under which the total amount of the fee payable to the agent or attorney (i) is to be paid to the attorney by the Secretary directly from any past-due benefits awarded on the basis of the claim, and (ii) is contingent on whether the matter is resolved in a manner favorable to the claimant or appellant, the total fee payable to the attorney or agent may not exceed 20 percent of the total amount of any past due benefits awarded on the basis of the claim. A claim shall be considered to have been resolved in a manner favorable to the claimant or appellant if all or any part of the relief sought is granted. 38 U.S.C. § 5904(d); 38 C.F.R. §§ 14.636(h)(1), 14.636(h)(2).

The term “past-due benefits” means a nonrecurring payment resulting from a benefit, or benefits, granted on appeal or awarded on the basis of a readjudicated claim after a denial by an AOJ or the Board or the lump sum payment that represents the total amount of recurring cash payments that accrued between the effective date of the award and the date of the grant of the benefit by the AOJ, the Board, or an appellate court. 38 C.F.R. § 14.636(h)(3). The fees are payable to the attorney based on the amount of past-due benefits awarded regardless of the amount payable to the Veteran. See Rosinski v. Wilkie, 32 Vet. App. 264 (2020); see also Gumpenberger v. Wilkie, 973 F.3d 1379 (Fed. Cir. 2020); Jackson v. McDonald, 635 Fed. Appx. 858 (Fed. Cir. 2015); Snyder v. Nicholson, 489 F.3d 1213 (Fed. Cir. 2007).

When the benefit granted on appeal, or as the result of the readjudicated claim, is service connection for a disability, the “past-due benefits” will be based on the initial disability rating assigned by the AOJ following the award of service connection. The sum will equal the payments accruing from the effective date of the award to the date of the initial disability rating decision.

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Related

Snyder v. Nicholson
489 F.3d 1213 (Federal Circuit, 2007)
Jackson v. McDonald
635 F. App'x 858 (Federal Circuit, 2015)
Gumpenberger v. Wilkie
973 F.3d 1379 (Federal Circuit, 2020)

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Bluebook (online)
190531-99372, Counsel Stack Legal Research, https://law.counselstack.com/opinion/190531-99372-bva-2020.