200423-80226

CourtBoard of Veterans' Appeals
DecidedJuly 14, 2021
Docket200423-80226
StatusUnpublished

This text of 200423-80226 (200423-80226) 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
200423-80226, (bva 2021).

Opinion

Citation Nr: AXXXXXXXX Decision Date: 07/14/21 Archive Date: 07/14/21

DOCKET NO. 200423-80226 DATE: July 14, 2021

ORDER

Entitlement to an effective date of January 1, 2008 for a total disability rating for compensation based on individual unemployability due to service-connected disabilities (TDIU) is granted.

REMANDED

Entitlement to a rating in excess of 20 percent for residuals, status-post severe left ankle sprain is remanded.

FINDING OF FACT

Resolving all reasonable doubt in favor of the Veteran, he was unable to obtain or maintain gainful employment due to his service-connected disabilities since January 1, 2008.

CONCLUSION OF LAW

The criteria for entitlement to an effective date prior of January 1, 2008 for the grant of TDIU have been met. 38 U.S.C. §§ 5110, 7105; 38 C.F.R. §§ 3.1, 3.104, 3.155, 3.400, 20.305.

REASONS AND BASES FOR FINDING AND CONCLUSION

The Veteran had active duty from February 1984 to August 1988.

This matter comes before the Board of Veterans' Appeals (Board) from a February 2020 rating decision of a Regional Office (RO) of the Department of Veterans Affairs (VA). The rating decision constitutes an initial decision; therefore, the modernized review system, also known as the Appeals Modernization Act (AMA), applies.

In October 2019, the Veteran submitted a VA Form 20-0996, Decision Review Request: Higher-Level Review (HLR), and requested review of a September 2019 rating decision that granted entitlement to a TDIU. In February 2020, the agency of original jurisdiction (AOJ) issued the HLR decision on appeal, which considered the evidence of record at the time of the initial rating decision. Therefore, the Board may only consider the evidence of record at the time of the initial rating decision.

In the April 2020 VA Form 10182, Decision Review Request: Board Appeal, the Veteran elected the Direct Review docket. 38 C.F.R. § 20.301.

1. TDIU Prior to October 4, 2018

The Veteran asserts that a TDIU rating is warranted in his case for the period prior to October 4, 2018, as he was unemployable due to service-connected disabilities before that date. The Veteran is currently in receipt of TDIU, effective October 4, 2018.

To establish a total disability rating based on individual unemployability, there must be impairment so severe that it is impossible for the average person to follow a substantially gainful occupation. 38 C.F.R. § 3.340. Substantially gainful employment is defined as work which is more than marginal and which permits the individual to earn a living wage. Moore v. Derwinski, 1 Vet. App. 356 (1991). In Faust v. West, 13 Vet. App. 342 (2000), the U.S. Court of Veterans Appeals (now the U.S. Court of Appeals for Veterans Claims) (Court) defined substantially gainful employment as "an occupation that provides an annual income that exceeds the poverty threshold for one person, irrespective of the number of hours or days that the Veteran actually works and without regard to the Veteran's earned annual income."

In Moore, the Court discussed the meaning of "substantially gainful employment." In this context, it noted the following standard announced by the United States Federal Court of Appeals in Timmerman v. Weinberger, 510 F.2d 439, 442 (8th Cir. 1975): "It is clear that the claimant need not be a total 'basket case' before the courts find that there is an inability to engage in substantial gainful activity. The question must be looked at in a practical manner, and mere theoretical ability to engage in substantial gainful employment is not a sufficient basis to deny benefits. The test is whether a particular job is realistically within the physical and mental capabilities of the claimant." Id. at 359.

VA will grant TDIU when the evidence shows that the veteran is precluded, by reason of service-connected disabilities, from obtaining and maintaining a substantially gainful occupation consistent with education and occupational experience, without regard to advancing age. 38 C.F.R. §§ 3.340, 3.341, 4.16 (2019).

Under the applicable regulations, TDIU may be granted only when it is established that the service-connected disabilities are so severe, standing alone, as to prevent the obtaining and maintaining of substantially gainful employment. If there is only one such disability, this disability shall be ratable at 60 percent or more. If there are two or more service-connected disabilities, there must be at least one disability rated 40 percent or more, and sufficient additional disabilities to bring the combined rating to 70 percent or more. 38 C.F.R. § 4.16 (a) (2019).

For the above purpose of one 60 percent disability, or one 40 percent disability in combination, the following will be considered as one disability: (1) Disabilities of one or both upper extremities, or of one or both lower extremities, including the bilateral factor, if applicable; (2) Disabilities resulting from common etiology or a single accident; (3) Disabilities affecting a single body system, e.g. orthopedic, digestive, respiratory, cardiovascular-renal, neuropsychiatric; (4) Multiple injuries incurred in action; or (5) Multiple disabilities incurred as a prisoner of war. Id.

Marginal employment is not considered substantially gainful employment and generally is 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 in certain cases when earned annual income exceeds the poverty threshold on a facts-found basis. Consideration shall be given in all claims to the nature of the employment and the reason for termination. 38 C.F.R. § 4.16(a). Marginal employment, odd-job employment, and employment at half the usual remuneration is not incompatible with a determination of unemployability if the restriction to securing or retaining better employment is due to disability. 38 C.F.R. § 4.17(a).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Faust v. West
13 Vet. App. 342 (Veterans Claims, 2000)
Moore v. Derwinski
1 Vet. App. 356 (Veterans Claims, 1991)
Fenderson v. West
12 Vet. App. 119 (Veterans Claims, 1999)
Correia v. McDonald
28 Vet. App. 158 (Veterans Claims, 2016)

Cite This Page — Counsel Stack

Bluebook (online)
200423-80226, Counsel Stack Legal Research, https://law.counselstack.com/opinion/200423-80226-bva-2021.