200409-76358

CourtBoard of Veterans' Appeals
DecidedFebruary 26, 2021
Docket200409-76358
StatusUnpublished

This text of 200409-76358 (200409-76358) 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
200409-76358, (bva 2021).

Opinion

Citation Nr: AXXXXXXXX Decision Date: 02/26/21 Archive Date: 02/26/21

DOCKET NO. 200409-76358 DATE: February 26, 2021

ORDER

Entitlement to disability ratings in excess of 10 percent for bilateral knee degenerative arthritis, based on limitation of flexion, are denied.

Entitlement to disability ratings in excess of 10 percent for bilateral knee recurrent subluxation are denied.

Entitlement to effectives date prior to February 5, 2008, for the award of service connection for bilateral knee degenerative arthritis, including on the basis of clear and unmistakable error (CUE), are denied.

Entitlement to effective dates prior to April 8, 2016, for the award of service connection for bilateral knee recurrent subluxation are denied.

FINDINGS OF FACT

1. The preponderance of the evidence shows that the Veteran's bilateral knee disability is not manifested by limitation of flexion to 30 degrees; limitation of extension to 0 degrees; moderate or severe recurrent subluxation or lateral instability; knee sprain, incomplete ligament tear, or complete ligament tear; ankylosis; nonunion of the tibia and fibula; dislocated semilunar cartilage; removal of semilunar cartilage; or genu recurvatum.

2. The claim upon which the reopened claim for service connection for a bilateral knee disability was granted was received on February 5, 2008.

3. In determining service connection for a bilateral knee disability was not warranted, the June 1977 Board decision was consistent with, and reasonably supported by, the evidence then of record and existing legal authority, and did not contain undebatable errors of fact or law that would have manifestly changed the outcome.

4. During and approximate to the pendency of the appeal, the preponderance of the evidence does not show that the Veteran’s bilateral knee disability was manifest by recurrent subluxation or lateral instability prior to April 8, 2016.

CONCLUSIONS OF LAW

1. The criteria for disability ratings in excess of 10 percent for bilateral knee degenerative arthritis, based on limitation of flexion, are not met. 38 U.S.C. §§ 1155, 5107, 5110; 38 C.F.R. §§ 3.102, 4.1, 4.7, 4.40, 4.45, 4.59, 4.71a.

2. The criteria for disability ratings in excess of 10 percent for bilateral knee recurrent subluxation are not met. 38 U.S.C. §§ 1155, 5107, 5110; 38 C.F.R. §§ 3.102, 4.1, 4.7, 4.40, 4.45, 4.59, 4.71a.

3. The June 1977 Board decision that denied service connection for a bilateral knee disability was not clearly and unmistakably erroneous. 38 U.S.C. § 7111; 38 C.F.R. §§ 20.1400-20.1411.

4. The criteria for effective dates prior to February 5, 2008, for the award of service connection for bilateral knee degenerative arthritis have not been met. 38 U.S.C. §§ 5101, 5107, 5110; 38 C.F.R. § 3.102, 3.105, 3.400.

5. The criteria for effective dates prior to April 8, 2016, for the award of service connection for bilateral knee subluxation have not been met. 38 U.S.C. §§ 5101, 5107, 5110; 38 C.F.R. § 3.102, 3.105, 3.400.

REASONS AND BASES FOR FINDINGS AND CONCLUSIONS

On August 23, 2017, the Veterans Appeals Improvement and Modernization Act, Pub. L. No. 115-55 (codified as amended in scattered sections of 38 U.S.C.), 131 Stat. 1105 (2017), also known as the Appeals Modernization Act (AMA), was signed into law. This law creates a new framework for Veterans dissatisfied with VA’s decision on their claim to seek review. This decision has been written consistent with the new AMA framework.

The Veteran served on active duty in the United States Army from February 1975 to July 1976.

These matters come before the Board of Veterans' Appeals (Board) on appeal of February 2018 and March 2019 rating decisions of the Department of Veterans Affairs (VA) Regional Office (RO).

The Veteran appealed these decisions to the Board in a March 2020 notice of disagreement (VA Form 10182), opting into AMA from a February 2020 statement of the case (SOC), and requested direct review by a Veteran's Law Judge.

Increased Ratings

Disability evaluations are determined by the application of a schedule of ratings which is based, as far as can practically be determined, on the average impairment of earning capacity. 38 U.S.C. § 1155; 38 C.F.R. § 4.1. Each service-connected disability is rated on the basis of specific criteria identified by Diagnostic Codes. 38 C.F.R. § 4.27. When rating the Veteran’s service-connected disability, the entire medical history must be borne in mind. Schafrath v. Derwinski, 1 Vet. App. 589 (1991). Separate higher or lower compensable evaluations may be assigned for separate periods of time if such distinct periods are shown by the competent evidence of record during the appeal, a practice known as “staged” ratings. See Hart v. Mansfield, 21 Vet. App. 505 (2007); Fenderson v. West, 12 Vet. App. 119, 126 (1999).

Regulations require that where there is a question as to which of two evaluations is to be applied, the higher evaluation will be assigned if the disability picture more nearly approximates the criteria required for that rating. Otherwise, the lower rating will be assigned. 38 C.F.R. § 4.7.

The assignment of a particular diagnostic code to evaluate a disability is "completely dependent on the facts of a particular case." See Butts v. Brown, 5 Vet. App. 532, 538 (1993). One diagnostic code may be more appropriate than another based on such factors as an individual's relevant medical history, the diagnosis, and demonstrated symptomatology.

The intent of the rating schedule is to recognize painful motion with joint or periarticular pathology as productive of disability. Thus, with or without degenerative arthritis, it is the intention to recognize actually painful, unstable, or malaligned joints, due to healed injury, as entitled to at least the minimum compensable rating for the joint. 38 C.F.R. § 4.59; see Burton v. Shinseki, 25 Vet. App. 1, 5 (2011) (holding that the provisions of 38 C.F.R. § 4.59 are not limited to disabilities involving arthritis).

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Gilbert v. Derwinski
1 Vet. App. 49 (Veterans Claims, 1990)
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3 Vet. App. 223 (Veterans Claims, 1992)
Russell v. Principi
3 Vet. App. 310 (Veterans Claims, 1992)
Butts v. Brown
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6 Vet. App. 242 (Veterans Claims, 1994)
Caffrey v. Brown
6 Vet. App. 377 (Veterans Claims, 1994)
Owens v. Brown
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200409-76358, Counsel Stack Legal Research, https://law.counselstack.com/opinion/200409-76358-bva-2021.