200326-75570

CourtBoard of Veterans' Appeals
DecidedJanuary 29, 2021
Docket200326-75570
StatusUnpublished

This text of 200326-75570 (200326-75570) 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
200326-75570, (bva 2021).

Opinion

Citation Nr: AXXXXXXXX Decision Date: 01/29/21 Archive Date: 01/29/21

DOCKET NO. 200326-75570 DATE: January 29, 2021

ORDER

The petition to reopen a previously denied claim for service connection for hypertension is granted.

Service connection for hypertension is granted.

FINDINGS OF FACT

1. New evidence was received after an unappealed February 1968 rating decision that is relevant to the issue of entitlement to service connection for hypertension.

2. The Veteran has current diagnosis of hypertension.

3. The Veteran served in the Republic of Vietnam in 1966 and is therefore presumed to have been exposed to herbicide agents therein.

4. Epidemiologic evidence concludes that there is a positive association between hypertension and exposure to herbicide agents, including Agent Orange.

5. The evidence is at least in equipoise as to whether the Veteran’s currently diagnosed hypertension is related to his exposure to herbicide agents during service.

CONCLUSIONS OF LAW

1. The criteria for readjudicating the claim for service connection for hypertension are met. 38 C.F.R. § 3.156(d) (2019).

2. The criteria to establish service connection for hypertension are met. 38 U.S.C. §§ 1110, 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 in the United States Naval Reserve, with active duty service from August 1965 to May 1967, including service in the Republic of Vietnam.

The February 2020 rating decision on appeal was issued under the new Appeals Modernization Act (AMA) framework, and the Veteran initiated the appeal to the Board March 2020 with the filing of a Decision Review Request (VA Form 10182), requesting direct review by a Veterans Law Judge on the evidence of record at the time of the rating decision. In correspondence dated May 2020, the Board acknowledged the appeal and informed the Veteran and his representative that the appeal had been placed on the Board’s direct review docket. Under the AMA, when a claimant seeks appellate review through the Board’s direct review docket, the Board may consider the evidence of record at the time of the rating decision on appeal, here as of February 26, 2020. 38 U.S.C. § 7113(a) (2019). The Board notes that potentially relevant evidence was added to the electronic claims file during a period of time when the record was closed and therefore, the Board may not consider this evidence at this time.

New and Relevant Evidence

The new and material evidence issue regarding the right knee disability has been recharacterized to reflect the applicable evidentiary (new and relevant evidence) standard under the AMA. 38 C.F.R. § 3.156(b). VA will readjudicate a claim if new and relevant evidence is presented or secured. 38 C.F.R. § 3.156(d). “Relevant evidence” is evidence that tends to prove or disprove a matter in issue. 38 C.F.R. § 3.2501(a)(1).

Here, the Board finds new evidence has been received after the prior final rating decision in the legacy system that is relevant to the claim of service connection for hypertension. Specifically, subsequent to the prior final rating decision dated February 1968 that denied service connection, a VA examination report and medical opinion were obtained in September 2019 and associated with the electronic claims file. This evidence relates to the unestablished element of a nexus with service. Therefore, the evidence is new and relevant and, to this extent only, the petition to reopen the claim for service connection for hypertension is granted.

Service Connection

Applicable Laws and Regulations

Service connection will be granted if the evidence demonstrates that a current disability resulted from an injury or disease incurred in or aggravated by active service. 38 U.S.C. § 1110; 38 C.F.R. § 3.303(a). Service connection may also be granted for any injury or disease diagnosed after discharge, when all the evidence, including that pertinent to service, establishes that the disease or injury was 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 current disability. Shedden v. Principi, 381 F.3d 1163, 1167 (Fed. Cir. 2004).

The existence of a current disability is the cornerstone of a claim for VA disability compensation. See Degmetich v. Brown, 104 F. 3d 1328 (1997); Brammer v. Derwinski, 3 Vet. App. 223, 225 (1992).

Hypertension is considered a “chronic” disease under 38 C.F.R. § 3.309(a). Therefore, the presumptive service connection provisions under 38 C.F.R. § 3.303(b) for service connection based on “chronic” symptoms in service and “continuous” symptoms since service must be considered in reviewing the instant claim. Walker v. Shinseki, 708 F.3d 1331 (Fed. Cir. 2013). For the showing of chronic diseases in service, there is required a combination of manifestations sufficient to identify the disease entity, and sufficient observation to establish chronicity at the time. With chronic disease as such in service, subsequent manifestations of the same chronic disease at any later date, however remote, are service-connected, unless clearly attributable to intercurrent causes. If a condition noted during service is not shown to be chronic, then generally, a showing of continuity of symptoms after service is required for service connection. 38 C.F.R. § 3.303(b). If not manifest during service, where a veteran served continuously for 90 days or more during a period of war, or during peacetime service after December 31, 1946, and the ‘chronic’ disease became manifest to a degree of 10 percent within one year from date of termination of such service, such disease shall be presumed to have been incurred in service, even though there is no evidence of such disease during the period of service. 38 C.F.R. § 3.307.

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200326-75570, Counsel Stack Legal Research, https://law.counselstack.com/opinion/200326-75570-bva-2021.