200422-75785

CourtBoard of Veterans' Appeals
DecidedMarch 31, 2021
Docket200422-75785
StatusUnpublished

This text of 200422-75785 (200422-75785) 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
200422-75785, (bva 2021).

Opinion

Citation Nr: AXXXXXXXX Decision Date: 03/31/21 Archive Date: 03/31/21

DOCKET NO. 200422-75785 DATE: March 31, 2021

ORDER

Whether there was clear and unmistakable error (CUE) in the April 1992 rating decision that denied entitlement to service connection for tinnitus is denied.

Whether there was CUE in the April 1992 rating decision that denied entitlement to service connection for a cervical spine (neck) disability is denied.

FINDINGS OF FACT

1. No CUE was made in the April 1992 rating decision that denied entitlement to service connection for tinnitus.

2. No CUE was made in the April 1992 rating decision that denied entitlement to service connection for a neck disability.

CONCLUSIONS OF LAW

1. The criteria for whether there was CUE in the April 1992 rating decision that denied entitlement to service connection for tinnitus have not been met. 38 U.S.C. §§ 5109A, 7105; 38 C.F.R. §§ 3.105.

2. The criteria for whether there was CUE in the April 1992 rating decision that denied entitlement to service connection for a neck disability have not been met. 38 U.S.C. §§ 5109A, 7105; 38 C.F.R. §§ 3.105.

REASONS AND BASES FOR FINDINGS AND CONCLUSIONS

The Veteran had active military service from July 1985 to October 1990.

On August 23, 2017, the President signed into law 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). This law creates a new framework for Veterans dissatisfied with decisions decided by the Department of Veterans Affairs (VA) on their claim to seek review. This decision has been written consistent with the new AMA framework.

In an October 2019 rating decision, the Regional Office (RO) found no CUE in an April 1992 rating decision that denied service connection for tinnitus and a neck disability. In September 2019, pursuant to a VA Form 10182, the Veteran opted for direct review of the CUE issue by the Board of Veterans’ Appeals (Board). Direct review is the appeal option to the Board in which a Board decision is issued based on evidence of record at the time of the prior decision. The Board cannot hold a hearing or accept into the record additional evidence in its direct review.

CUE

Generally, an unappealed rating decision becomes final within one year of its issuance. 38 C.F.R. § 20.1103. An exception to this finality rule is when clear and unmistakable error is found in the rating decision; a finding of CUE has the same effect as if the correct decision had been made on the date of the prior decision. 38 U.S.C. § 5109A; 38 C.F.R. §§ 3.104(a), 3.105(a).

CUE is a very specific and rare kind of error. 38 C.F.R. § 20.1403(a). It is the kind of error of fact or law which, when called to the attention of later reviewers, compels the conclusion, to which reasonable minds could not differ, that the result would have been manifestly different but for the error. 38 C.F.R. § 20.1403(a); see Russell v. Principi, 3 Vet. App. 310, 313-14 (1992) (en banc); see also Bustos v. West, 179 F.3d 1378, 1380-81 (Fed. Cir. 1999).

To establish CUE, the appellant must show: (1) that either the facts known at the time were not before the adjudicator or the law then in effect was incorrectly applied, (2) that an error occurred based on the record and the law that existed at the time the decision was made, and (3) that, had the error not been made, the outcome would have been manifestly different. See Bouton v. Peake, 23 Vet. App. 70, 71 (2008); Grover v. West, 12 Vet. App. 109, 112 (1999); Damrel v. Brown, 6 Vet. App. 242, 245 (1994); Russell, 3 Vet. App. at 313-14. If it is not absolutely clear that a different result would have ensued, the error complained of cannot be CUE. See 38 C.F.R. § 20.1403(b), (c); see also Bustos v. West, 179 F.3d 1378 (Fed. Cir. 1999).

Even when the premise of error is accepted, if it is not absolutely clear that a different result would have ensued, the error complained of cannot be ipso facto clear and unmistakable. Fugo v. Brown, 6 Vet. App. 40, 43-44 (1993) (citing Russell, 3 Vet. App. at 313). A determination of CUE must be based on the record and the law that existed at the time of the prior adjudication. Baldwin v. West, 13 Vet. App. 1 (1999); Caffrey v. Brown, 6 Vet. App. 377 (1994).

1. Whether there was CUE in the April 1992 rating decision that denied entitlement to service connection for tinnitus

2. Whether there was CUE in the April 1992 rating decision that denied entitlement to service connection for a neck disability

The Veteran asserts CUE in the April 1992 rating decision that denied the claims for service connection for a neck disability and tinnitus (the Board observes that service connection for both tinnitus and neck disability have been in effect since February 2013). The Veteran argues that the RO failed to correctly apply 38 U.S.C. § 3.303 (1992) at the time of the April 1992 rating decision. The law in effect in 1992 required a current disability, in-service incurrence, and a nexus between the two. Further, if there is a chronic disease, such is service connected if there is required combination of manifestations sufficient at the time as distinguished from merely isolated findings or diagnosis including the word “chronic.” Continuity of symptomatology was required only where the condition noted during service or in the presumptive period is not, in fact, shown to be chronic or where the diagnosis of chronicity may be legitimately questioned. See 38 U.S.C.§§ 3.303. 3.307 (1992).

After reviewing the claims file, the Board finds that the evidence of record fails to show CUE in the April 1992 rating decision.

The Veteran filed a claim for service connection for a number of disabilities in November 1990, approximately one month following separation from active service, to include claims for service connection for a whiplash injury in 1989 (neck) and a training incident resulting in hearing loss in 1985. Accordingly, he was afforded a VA audiological examination in February 1992 and a VA orthopedic examination in March 1992.

The orthopedic examiner noted headache, neck, and right trapezius muscle pain. However, when asked to prioritize his medical issues, the Veteran stated that his left knee and right shoulder were the most bothersome.

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Related

John P. Bouton v. James B. Peake
23 Vet. App. 70 (Veterans Claims, 2008)
Russell v. Principi
3 Vet. App. 310 (Veterans Claims, 1992)
Fugo v. Brown
6 Vet. App. 40 (Veterans Claims, 1993)
Damrel v. Brown
6 Vet. App. 242 (Veterans Claims, 1994)
Caffrey v. Brown
6 Vet. App. 377 (Veterans Claims, 1994)
Layno v. Brown
6 Vet. App. 465 (Veterans Claims, 1994)
Luallen v. Brown
8 Vet. App. 92 (Veterans Claims, 1995)
Grover v. West
12 Vet. App. 109 (Veterans Claims, 1999)
Baldwin v. West
13 Vet. App. 1 (Veterans Claims, 1999)

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200422-75785, Counsel Stack Legal Research, https://law.counselstack.com/opinion/200422-75785-bva-2021.