200212-62305

CourtBoard of Veterans' Appeals
DecidedDecember 31, 2020
Docket200212-62305
StatusUnpublished

This text of 200212-62305 (200212-62305) 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
200212-62305, (bva 2020).

Opinion

Citation Nr: AXXXXXXXX Decision Date: 12/31/20 Archive Date: 12/31/20

DOCKET NO. 200212-62305 DATE: December 31, 2020

ORDER

Entitlement to a total disability rating for compensation based on individual unemployability due to service-connected disabilities (TDIU) is denied.

FINDING OF FACT

The Veteran is not precluded from securing or following a substantially gainful occupation due to her service-connected disabilities.

CONCLUSION OF LAW

The criteria for entitlement to a TDIU rating have not been met. 38 U.S.C. §§ 1155, 5107; 38 C.F.R. §§ 3.102, 3.340, 3.341, 4.16.

REASONS AND BASES FOR FINDING AND CONCLUSION

The Veteran served on active duty from April 1977 to November 1977 with additional service in the National Guard thereafter.

This matter is before the Board on appeal of a January 2020 rating decision, having previously been deferred for further development in an April 2019 rating decision.

On August 23, 2017, the President signed into law the Veterans Appeals Improvement and Modernization Act, also known as the Appeals Modernization Act (AMA). Pub. L. No. 115055 (to be codified ast amended in scattered sections of 38 U.S.C.), 131 Stat. 1105 (2017). This law creates a new framework for veterans to seek review of their claims. In February 2020, the Veteran submitted a VA Form 10182 Notice of Disagreement which selected the Direct Review docket, indicating that the Veteran does not wish to have a Board hearing and which considers only the evidence of record at the time of the rating decision on appeal. As such, although the Veteran did submit additional evidence thereafter, the Board may only consider the evidence available to the Agency of Original Jurisdiction (AOJ) when the rating decision on appeal was issued, January 15, 2020.

The Veteran has alleged that chronic back pain limits her mobility, her ability to bend and lift, and her ability to sit, stand, or walk for prolonged periods. The Veteran has also reported that incontinence requires frequent bathroom breaks and causes her to have several accidents per day.

Total disability will be considered to exist where there is present any impairment of mind and body that is sufficient to render it impossible for the average person to follow a substantially gainful occupation. 38C.F.R. §3.340. Total disability ratings for compensation may be assigned, where the schedular rating is less than total and when the disabled person is unable to secure or follow a substantially gainful occupation because of service-connected disabilities, provided that the Veteran meets the schedular requirements.

Specifically, if there is only one such disability, the disability shall be ratable at 60 percent or more; if there are two or more disabilities, there shall be at least one disability that is ratable at 40 percent or more and enough additional disability to bring the combined rating to 70 percent or more. 38 C.F.R. §§ 3.340, 3.341, 4.16(a).

The question of unemployability or the veteran's ability or inability to engage in substantial gainful activity must be examined in a practical manner. The crux of the matter rests upon whether a particular job is realistically within the capabilities, both physical and mental, of the appellant.

Marginal employment shall not be considered substantially gainful employment and generally shall be deemed to exist when a veteran's earned income does not exceed the amount established by the U.S. Department of Commerce, Bureau of the Census, as the poverty threshold for one person. Marginal employment may also be held to exist, on a facts-found basis (includes but is not limited to employment in a protected environment such as a family business or sheltered workshop), when earned annual income exceeds the poverty threshold.

The Board shall consider the nature of the employment and the reason for any termination. 38 C.F.R. § 4.16(a). The central inquiry is "whether the veteran's service-connected disabilities alone are of sufficient severity to produce unemployability." Neither nonservice-connected disabilities nor advancing age may be considered in the determination. 38 C.F.R. §§ 3.341, 4.19.

The record must reflect some factor that takes the case outside the norm with respect to a similar level of disability under the rating schedule. 38 C.F.R. §§ 4.1, 4.15. The fact that a claimant is unemployed or has difficulty obtaining employment is not enough. The question is whether the Veteran can perform the physical and mental acts required by employment, not whether she can find employment.

"Substantially gainful employment" is that employment "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." Moore v. Derwinski,1 Vet. App. 356, 358 (1991). "Marginal employment shall not be considered substantially gainful employment." 38C.F.R. §4.16.

In determining whether a veteran can secure and follow a substantially gainful occupation, the United States Court of Appeals for Veterans Claims (Court) in Ray v. Wilkie directed the Board to consider the following factors: (1) the veteran's history, education, skill, and training; (2) whether the veteran has the physical ability (both exertional and non-exertional) to perform the type of activities required by the occupation at issue; and (3) whether the veteran has the mental ability to perform the activities required by the occupation at issue. 31 Vet. App. 58, 73 (2019).

In determining whether unemployability exists, consideration may be given to the Veteran's level of education, special training, and previous work experience, but not to her age or to any impairment caused by nonservice-connected disabilities. 38 C.F.R. §§ 3.341, 4.16, 4.19.

The responsibility for making the ultimate TDIU determination is placed on the adjudicator and not a medical examiner. See Geib v. Shinseki, 733 F.3d 1350, 1354 (Fed. Cir. 2013). A medical examiner's role is limited to describing the effects of disability upon the person's ordinary activity. See Floore v. Shinseki, 26 Vet. App. 376, 381 (2013).

The Board notes that, while multiple sources in the evidence of record reference the Veteran’s ability or inability to perform sedentary work, the term sedentary is not defined by VA regulations for TDIU. Rather, the meaning is to be determined on a case-by-case asis, including how the concept of sedentary work figures into the Veteran’s overall disability picture and vocational history. See Withers v. Wilkie, 30 Vet. App. 139 (2018). In this instance, the Board finds that a majority of the pertinent evidence has a shared understanding of what generally comprises sedentary work, which will be discussed further below. While some interpretations may vary, for purposes of this decision, sedentary work consists of work that requires exerting up to ten pounds of force no more than occasionally (one-third of the time) and or a negligible amount of force more often, to lift, carry, push, or pull.

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Related

Geib v. Shinseki
733 F.3d 1350 (Federal Circuit, 2013)
Jimmy H. Floore v. Eric K. Shinseki
26 Vet. App. 376 (Veterans Claims, 2013)
Moore v. Derwinski
1 Vet. App. 356 (Veterans Claims, 1991)

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200212-62305, Counsel Stack Legal Research, https://law.counselstack.com/opinion/200212-62305-bva-2020.