200819-105250

CourtBoard of Veterans' Appeals
DecidedDecember 31, 2020
Docket200819-105250
StatusUnpublished

This text of 200819-105250 (200819-105250) 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
200819-105250, (bva 2020).

Opinion

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

DOCKET NO. 200819-105250 DATE: December 31, 2020

ORDER

1. Service connection for hypertension is denied.

2. For the period from January 23, 2018 forward, a rating in excess of 10 percent for an unspecified anxiety disorder is denied.

3. Service connection for a lumbar spine disability is denied.

4. Service connection for a deviated nasal septum is denied.

FINDINGS OF FACT

1. The Veteran currently has hypertension.

2. The Veteran did not experience an in-service injury, disease, or event related to hypertension.

3. Symptoms of hypertension were not chronic during service or continuous since service discharge, and did not manifest to a degree of 10 percent within one year of service discharge.

4. The current hypertension is not related to service.

5. For the period from January 23, 2018 forward, the Veteran’s unspecified anxiety disorder has more nearly approximated occupational and social impairment due to mild or transient symptoms which decrease work efficiency and ability to perform occupational tasks only during periods of significant stress.

6. The service treatment records are complete.

7. The Veteran has a current diagnosis of arthritis of the lumbar spine.

8. The Veteran did not experience a lumbar spine injury or disease during service.

9. Symptoms of arthritis were not chronic in service or continuous since service, and arthritis did not manifest to a compensable degree within one year of service.

10. The current lumbar spine disability is not related to service.

11. The Veteran does not have a current diagnosis of a deviated nasal septum.

CONCLUSIONS OF LAW

1. The criteria for service connection for hypertension have not been met. 38 U.S.C. §§ 1110, 1112, 1131, 5103, 5103A, 5107; 38 C.F.R. §§ 3.159, 3.102, 3.303, 3.307, 3.309.

2. The criteria for a rating in excess of 10 percent for the service-connected unspecified anxiety disorder have not been met for any period. 38 U.S.C. §§ 1155, 5103, 5103A; 38 C.F.R. §§ 3.159, 4.1, 4.3, 4.7, 4.130, Diagnostic Code 9413.

3. The criteria for service connection for a lumbar spine disability have not been met. 38 U.S.C. §§ 1101, 1112, 1110, 5103, 5103A, 5107; 38 C.F.R. §§ 3.159, 3.102, 3.303, 3.307, 3.309.

4. The criteria for service connection for a deviated nasal septum have not been met. 38 U.S.C. §§ 1110, 1131, 5103, 5103A, 5107; 38 C.F.R. §§ 3.102, 3.159, 3.303.

REASONS AND BASES FOR FINDINGS AND CONCLUSIONS

The Veteran served on active duty from September 1963 to September 1967. The Veteran declined a Board of Veterans Appeals (Board) hearing by selecting Direct Review by a Veterans Law Judge on the August 2020 VA Form 10182 Notice of Disagreement: Board Appeal.

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

In the July 2020 statement of the case (SOC) under the legacy appeals process, the agency of original jurisdiction (AOJ) found that new and material evidence had been submitted to warrant re-opening the claim for service connection for hypertension. Under the new AMA process, new and relevant evidence (a lower threshold), is used to determine whether a claim should be reopened and readjudicated on its underlying merits. As new and material evidence (and therefore new and relevant evidence as well) was found by the AOJ, the Board will accept this finding and proceed immediately to re-adjudicate the claim on its underlying merits, meaning on a de novo basis.

Service Connection Legal Authority

Service connection may be granted for a disability resulting from disease or injury incurred in or aggravated by active service. 38 U.S.C. §§ 1110, 1131; 38 C.F.R. §§ 3.303(a). Service connection may be granted for any disease diagnosed after discharge, when all the evidence, including that pertinent to service, establishes that the disease was incurred in service. 38 C.F.R. §§ 3.303(d). 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.

Where the evidence shows a “chronic disease” such as arthritis or hypertension in service or “continuity of symptoms” after service, the disease shall be presumed to have been incurred in service. For the showing of “chronic” disease 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 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).

Additionally, where a veteran served 90 days or more of active service, and certain chronic diseases, such as arthritis or hypertension, become manifest to a degree of 10 percent or more within one year after the date of separation from 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. While the disease need not be diagnosed within the presumption period, it must be shown, by acceptable lay or medical evidence, that there were characteristic manifestations of the disease to the required degree during that time. 38 C.F.R. §§ 3.307, 3.309(a).

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200819-105250, Counsel Stack Legal Research, https://law.counselstack.com/opinion/200819-105250-bva-2020.