190731-72833

CourtBoard of Veterans' Appeals
DecidedJune 30, 2020
Docket190731-72833
StatusUnpublished

This text of 190731-72833 (190731-72833) 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
190731-72833, (bva 2020).

Opinion

Citation Nr: AXXXXXXXX Decision Date: 06/30/20 Archive Date: 06/30/20

DOCKET NO. 190731-72833 DATE: June 30, 2020

ORDER

Service connection for a traumatic brain injury (TBI) is granted.

REMANDED

Entitlement to service connection for tinnitus is remanded.

Entitlement to service connection for a bilateral hearing loss disability is denied.

FINDING OF FACT

In a February 2006 rating decision, the RO awarded service connection for “laceration to scalp (claimed as head injury).” Therefore, service connection for a TBI has already implicitly been awarded.

CONCLUSION OF LAW

The criteria for entitlement to service connection for a TBI have been met. 38 U.S.C. §§ 1131, 5107 (2012); 38 C.F.R. §§ 3.102, 3.303 (2019).

REASONS AND BASES FOR FINDINGS AND CONCLUSIONS

The Veteran, who is the appellant in this case, served on active duty from August 1979 to April 1985.

This matter comes before the Board of Veterans’ Appeals (Board) on appeal from a May 2019 decision of a Department of Veterans Affairs (VA) Regional Office (RO). In July 2019, the Veteran timely selected direct review by the Board and this appeal ensued.

In the May 2019 rating decision on appeal, the RO reopened and readjudicated the previously denied claims for service connection for tinnitus, a bilateral hearing loss disability, and a TBI. When the Agency of Original Jurisdiction (AOJ) reopens a previously denied claim under the Appeals Modernization Act framework, as applicable here, the Board is bound by this favorable finding and is not required to make an independent determination as to whether the previously denied claim should be reopened before addressing the merits of the underlying claim. See 38 C.F.R. § 20.801. Accordingly, no further analysis is necessary regarding whether the claims warrant reopening. See AMA, Pub. L. No. 115-55

§ 5104A, 131 Stat. 1105, 1106-07.

The Board has limited the discussion below to the relevant evidence required to support its finding of fact and conclusion of law, as well as to the specific contentions regarding the case as raised directly by the Veteran and those reasonably raised by the record. See Scott v. McDonald, 789 F.3d 1375, 1381 (Fed. Cir. 2015); Robinson v. Peake, 21 Vet. App. 545, 552 (2008); Dickens v. McDonald, 814 F.3d 1359, 1361 (Fed. Cir. 2016).

Service Connection

Service connection may be granted for a disability resulting from disease or injury incurred in or aggravated by active military, naval, or air service. 38 U.S.C. § 1110; 38 C.F.R. § 3.303(a). Service connection may also be granted for any disease diagnosed after discharge, when all the evidence, including that pertinent to service, establishes that the disease incurred in service. 38 C.F.R. § 3.303(d).

Establishing service connection generally requires (1) medical evidence of a current disability; (2) medical or, in certain circumstances, lay evidence of in-service incurrence or aggravation of a disease or injury; and (3) medical evidence of a nexus between the claimed in-service disease or injury and the present disability. Shedden v. Principi, 381 F.3d 1163, 1167 (Fed. Cir. 2004).

In rendering a decision on appeal, the Board must analyze the credibility and probative value of the evidence, account for the evidence which it finds to be persuasive or unpersuasive, and provide the reasons for its rejection of any material favorable to the claimant. Gabrielson v. Brown, 7 Vet. App. 36, 39-40 (1994); Gilbert v. Derwinski, 1 Vet. App. 49, 57 (1990). Competency of evidence differs from weight and credibility. Competency is a legal concept determining whether testimony may be heard and considered by the trier of fact, while credibility is a factual determination going to the probative value of the evidence to be made after the evidence has been admitted. Rucker v. Brown, 10 Vet. App. 67, 74 (1997); Layno v. Brown, 6 Vet. App. 465, 469 (1994).

When considering whether lay evidence is competent, the Board must determine, on a case-by-case basis, whether a veteran's particular disability is the type of disability for which lay evidence may be competent. Kahana v. Shinseki, 24 Vet. App. 428 (2011); see also Jandreau v. Nicholson, 492 F.3d 1372, 1376-77 (Fed. Cir. 2007). A veteran is competent to report symptoms because this requires only personal knowledge, not medical expertise, as it comes to him through his senses. See Layno, 6 Vet. App. 465, 469. Lay testimony is competent to establish the presence of observable symptomatology, where the determination is not medical in nature and is capable of lay observation. Barr v. Nicholson, 21 Vet. App. 303 (2007). Lay evidence may establish a diagnosis of a simple medical condition, a contemporaneous medical diagnosis, or symptoms that later support a diagnosis by a medical professional. Jandreau, 492 F.3d 1372, 1377.

When all the evidence is assembled, VA is responsible for determining whether the evidence supports the claim or is in relative equipoise, with a veteran prevailing in either event, or whether a preponderance of the evidence is against a claim, in which case, the claim is denied. 38 U.S.C. § 5107(b); 38 C.F.R. § 3.102.

1. Entitlement to service connection for a TBI.

The Veteran contends that he suffered a TBI during service, and currently experiences residual symptoms of the in-service TBI. Specifically, he reported that he was stuck by a manual traversing handle while operating a tank during service in 1983, which caused a head laceration.

In a February 2006 decision, the RO awarded service connection for “laceration to scalp (claimed as head injury),” as reflected on the rating code sheet.

Based on the February 2006 rating decision and the findings therein, the Board finds that service connection for a TBI has already been granted. The RO’s findings are clear that the Veteran has a scar as a result of a TBI/head trauma in service and that was the basis for the award of service connection. Therefore, the award of service connection for a TBI has already been implicitly granted by the award of service connection for a laceration to scalp (claimed as head injury). See Baughman v. Derwinski, 1 Vet. App. 563, 566 (1991) (listing a condition on a rating decision as part of a service connected disability has the effect of granting service connection).

For these reasons, the Board will explicitly award service connection for a TBI, in order to avoid any further confusion in this matter. See 38 C.F.R. §§ 3.102, 3.303.

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Related

Jandreau v. Nicholson
492 F.3d 1372 (Federal Circuit, 2007)
Jerry G. Dalton v. R. James Nicholson
21 Vet. App. 23 (Veterans Claims, 2007)
James P. Barr v. R. James Nicholson
21 Vet. App. 303 (Veterans Claims, 2007)
Rick K. Kahana v. Eric K. Shinseki
24 Vet. App. 428 (Veterans Claims, 2011)
Scott v. McDonald
789 F.3d 1375 (Federal Circuit, 2015)
Dickens v. McDonald
814 F.3d 1359 (Federal Circuit, 2016)
Gilbert v. Derwinski
1 Vet. App. 49 (Veterans Claims, 1990)
Baughman v. Derwinski
1 Vet. App. 563 (Veterans Claims, 1991)
Hensley v. Brown
5 Vet. App. 155 (Veterans Claims, 1993)
Layno v. Brown
6 Vet. App. 465 (Veterans Claims, 1994)
Gabrielson v. Brown
7 Vet. App. 36 (Veterans Claims, 1994)
Rucker v. Brown
10 Vet. App. 67 (Veterans Claims, 1997)
Robinson v. Mansfield
21 Vet. App. 545 (Veterans Claims, 2008)

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190731-72833, Counsel Stack Legal Research, https://law.counselstack.com/opinion/190731-72833-bva-2020.