201020-113953

CourtBoard of Veterans' Appeals
DecidedFebruary 26, 2021
Docket201020-113953
StatusUnpublished

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Bluebook
201020-113953, (bva 2021).

Opinion

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

DOCKET NO. 201020-113953 DATE: February 26, 2021

ORDER

Entitlement to service connection for chronic gastritis, to include as secondary to service-connected disabilities or their medications, is denied.

FINDING OF FACT

The most probative evidence of record weighs against a conclusion that the Veteran’s gastritis is etiologically related to his active duty service or to any service-connected disability.

CONCLUSION OF LAW

The criteria for service connection for chronic gastritis have not been met. 38 U.S.C. §§ 1110, 1131, 5103A, 5107 (West 2014); 38 C.F.R. §§ 3.102, 3.303, 3.310 (2018).

REASONS AND BASES FOR FINDING AND CONCLUSION

The Veteran served on active duty in the U.S. Army from December 1965 to September 1967.

This matter comes before the Board of Veterans’ Appeals (Board) as the result of an October 2020 rating decision from the Department of Veterans Affairs (VA) Regional Office (RO) in San Juan, Puerto Rico.

The Veteran submitted a VA Form 10182 in October 2020 and selected the Direct Review docket, indicating that he did not want a Board hearing. Included with his October 2020 appeal was the issue of entitlement to a total disability rating based on individual unemployability (TDIU). See April 2020 VA Form 10182, Notice of Disagreement. The issue of a TDIU was addressed in a separate Board decision and is no longer for appeal. See December 2020 Board decision.

The matter is now before the Board to address the issue of chronic gastritis.

This case has been advanced on the docket pursuant to 38 U.S.C. § 7107(b) and 38 C.F.R. § 20.902(c).

1. Service connection for chronic gastritis as secondary to service-connected disabilities.

The Veteran contends that his chronic gastritis is the result of his “medication intake.” See March 2020 VA Form 21-526EZ, Application for Disability Compensation.

In adjudicating the claim of entitlement to service connection for chronic gastritis, the Board may consider evidence associated with the record on October 2, 2020, the date the VA Rating Decision on appeal was issued by the RO.

Duty to Notify and Assist

Neither the Veteran nor his representative has raised any issues with the duty to notify or duty to assist. See Scott v. McDonald, 789 F.3d 1375, 1381 (Fed. Cir. 2015) (holding that “the Board’s obligation to read filings in a liberal manner does not require the Board...to search the record and address procedural arguments when the veteran fails to raise them before the Board”); Dickens v. McDonald, 814 F.3d 1359, 1361 (Fed. Cir. 2016) (applying Scott to a duty to assist argument).

Service Connection

Generally, to prevail on a claim for service connection on the merits, there must be competent evidence of (1) 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 or other competent evidence of a nexus between the claimed in-service disease or injury and the present disease or injury. See Hickson v. West, 12 Vet. App. 247 (1999); Jandreau v. Nicholson, 492 F.3d 1372 (Fed. Cir. 2007).

Service connection may also be established on a secondary basis for a disability which is proximately due to or the result of service-connected disease or injury. See generally 38 C.F.R. § § 3.310(a). Establishing service connection on a secondary basis requires evidence sufficient to show (1) that a current disability exists and (2) that the current disability was either (a) proximately caused by or (b) proximately aggravated by a service-connected disability. Allen v. Brown, 7 Vet. App. 439, 448 (1995) (en banc).

Lay evidence can be competent and sufficient to establish a diagnosis of a condition when (1) a layperson is competent to identify the medical condition, (2) the layperson is reporting a contemporaneous medical diagnosis, or (3) lay testimony describing symptoms at the time supports a later diagnosis by a medical professional. Jandreau v. Nicholson, 492 F.3d 1372, 1377 (Fed. Cir. 2007); see also Buchanan v. Nicholson, 451 F.3d 1331, 1337 (Fed. Cir. 2006) (“[T]he Board cannot determine that lay evidence lacks credibility merely because it is unaccompanied by contemporaneous medical evidence”).

The Board must determine, on a case by case basis, whether the Veteran’s particular disability is the type of disability for which lay evidence may be competent. Kahana v. Shinseki, 24 Vet. App. 428 (2011). Although the Veteran is competent to provide a diagnosis of an observable condition such as a headache, varicose veins, or tinnitus, the Veteran is not competent to provide evidence as to more complex medical questions, such as the etiology of gastrointestinal pathology. See Woehlaert v. Nicholson, 21 Vet. App. 456 (2007).

An alternative method of establishing the second and third elements of service connection is by establishing continuous symptoms since service. See Barr v. Nicholson, 21 Vet. App. 303, 307 (2007). Continuity of symptomatology may be established if a claimant can demonstrate (1) that a condition was “noted” during service; (2) evidence of post-service continuity of the same symptoms; and (3) medical or, in certain circumstances, lay evidence of a nexus (causal connection) between the present disability and the post-service symptoms. Savage v. Gober, 10 Vet. App. 488 (1997); 38 C.F.R. § 3.303(b). However, the theory of continuity of symptomatology can only be used in cases involving those medical conditions explicitly recognized as “chronic” under 38 C.F.R. § 3.309(a). See Walker v. Shinseki, 708 F.3d 1331 (Fed. Cir. 2013).

A Veteran is entitled to the benefit of the doubt when there is an approximate balance of positive and negative evidence on any issue material to the claim. See 38 U.S.C. § 5107 (West 2014); 38 C.F.R. § 3.102 (2016) (providing, in pertinent part, that reasonable doubt will be resolved in favor of the Veteran). When the evidence supports the claim or is in relative equipoise, the claim will be granted. See Gilbert v. Derwinski, 1 Vet. App. 49, 55 (1990); see also Wise v. Shinseki, 26 Vet. App. 517, 532 (2014). If the preponderance of the evidence weighs against the claim, it must be denied. See Id.; Alemany v. Brown, 9 Vet. App. 518, 519 (1996).

Analysis

The Veteran has not claimed, nor does the record indicate, in-service complaints, treatment, or a diagnosis for stomach or digestive disorders.

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Related

Jandreau v. Nicholson
492 F.3d 1372 (Federal Circuit, 2007)
King v. Dept. Of Veterans Affairs
700 F.3d 1339 (Federal Circuit, 2012)
James P. Barr v. R. James Nicholson
21 Vet. App. 303 (Veterans Claims, 2007)
Woehlaert v. Nicholson
21 Vet. App. 456 (Veterans Claims, 2007)
Angel S. Nieves-Rodriguez v. James B. Peake
22 Vet. App. 295 (Veterans Claims, 2008)
Rick K. Kahana v. Eric K. Shinseki
24 Vet. App. 428 (Veterans Claims, 2011)
Walker v. Shinseki
708 F.3d 1331 (Federal Circuit, 2013)
Ouida Wise v. Eric K. Shinseki
26 Vet. App. 517 (Veterans Claims, 2014)
Scott v. McDonald
789 F.3d 1375 (Federal Circuit, 2015)
Dickens v. McDonald
814 F.3d 1359 (Federal Circuit, 2016)
Gilbert v. Derwinski
1 Vet. App. 49 (Veterans Claims, 1990)
Allen v. Brown
7 Vet. App. 439 (Veterans Claims, 1995)
Alemany v. Brown
9 Vet. App. 518 (Veterans Claims, 1996)
Savage v. Gober
10 Vet. App. 488 (Veterans Claims, 1997)
Hickson v. West
12 Vet. App. 247 (Veterans Claims, 1999)
Jones v. West
12 Vet. App. 383 (Veterans Claims, 1999)

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