Richard Heller v. Denis McDonough

CourtUnited States Court of Appeals for Veterans Claims
DecidedNovember 21, 2024
Docket24-3504
StatusPublished

This text of Richard Heller v. Denis McDonough (Richard Heller v. Denis McDonough) is published on Counsel Stack Legal Research, covering United States Court of Appeals for Veterans Claims primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Richard Heller v. Denis McDonough, (Cal. 2024).

Opinion

Case: 24-3504 Page: 1 of 12 Filed: 11/21/2024

UNITED STATES COURT OF APPEALS FOR VETERANS CLAIMS

No. 24-3504

RICHARD HELLER, PETITIONER,

V.

DENIS MCDONOUGH, SECRETARY OF VETERANS AFFAIRS, RESPONDENT.

Before MEREDITH, TOTH, and FALVEY, Judges.

ORDER

Like too many of our Nation's veterans, the petitioner—Mr. Richard Heller—struggles with suicidal ideation. Despite receiving extensive evidence of his ideation and past suicide attempt and suicidal behavior, the Board of Veterans' Appeals denied Mr. Heller's multiple requests for his case to be advanced on the docket (AOD). The Board did so with a conclusory finding that he had presented insufficient supporting medical evidence to show that his illness was serious or grave enough to warrant advancement.

Mr. Heller petitions us for a writ of mandamus, asking that we order VA to issue a decision or to advance his case. At minimum, he wants us to order the Board to provide him with a reasoned explanation for why his case won't be advanced. This is a request that this Court reluctantly denied in a single-judge decision. But with expanded arguments and some new case law, Mr. Heller asked that the Court reconsider its denial and convene a panel to consider the important questions raised by his petition. The Court agreed and convened a panel to help clarify whether and in what context we can review AOD determinations from the Board.

Like other jurisdictional questions, the limits of our review of AOD determinations involves complicated questions. Questions that are made more complicated when this Court is asked to deal with those issues through an extraordinary writ. We've tried to answer some of these questions before, most recently in Hailey v. McDonough, No. 22-3061, 2024 WL 3101294 (Vet. App. June 24, 2024). In Hailey, we ultimately did not resolve anything because the Board decided the underlying benefits claim before we could issue a decision, leaving nothing to AOD. That's already happened here to one of Mr. Heller's claims.

As to Mr. Heller's mental health claim, we conclude that a Board denial of an AOD motion is not a final Board decision and is thus not appealable to this Court. However, because Mr. Heller's claim for benefits could be the subject of a Board decision, we may issue a writ if VA's action (or inaction) unreasonably delays the claim or otherwise puts our jurisdiction at risk. That's the path Mr. Heller chose in this case. And that's the action we're going to take. Case: 24-3504 Page: 2 of 12 Filed: 11/21/2024

Under the circumstances presented here, we conclude that Mr. Heller has shown that a writ is warranted. We have the authority to compel action of the Secretary that is unlawfully withheld or unreasonably delayed. Mr. Heller has presented 10 records showing severe suicidal ideation, together with financial hardship due to unemployment, and an appeal pending for over two years without any VA action. What's more, Congress authorized the Board to advance appeals such as this, providing some indication of the speed with which it expects the Board to proceed if someone is seriously ill or has financial hardship, yet the Board has provided only generic responses to Mr. Heller's repeated requests for faster processing and his mental health condition appeal has sat untouched since July 2022. Although there is no "hard and fast rule with respect to the point in time at which a delay becomes unreasonable," Martin v. O'Rourke, 891 F.3d 1338, 1346 (Fed. Cir. 2018), we conclude, under the unique circumstances of this case, that the factors for assessing whether an Agency has unreasonably delayed action weigh in Mr. Heller's favor. Thus, we will grant Mr. Heller's petition and order the Board to decide his mental health condition appeal within 30 days.

I. BACKGROUND

A. Mr. Heller's AOD Attempts

Congress gave VA authority to advance cases on its docket. 38 U.S.C. § 7107(b). This includes situations when "the appellant is seriously ill or is under severe financial hardship." 38 U.S.C. § 7107(b)(3)(B). And VA implemented this authority in 38 C.F.R. § 20.800(c)(1), essentially parroting the enumerated statutory reasons for advancing a case, including when the appellant is seriously ill or is under severe financial hardship. 38 C.F.R. § 20.800(c)(1) (2024).

Plagued, as many veterans are, by a multi-year wait for a Board decision, and struggling with suicidal ideation, Mr. Heller sought to have his case advanced by the Board. Hoping to qualify based on serious illness, he submitted much evidence showing his difficulties with suicidal ideation. This includes:

(1) a January 2022 medical record showing suicidal ideation in the past month—a "[w]ish to die," Petition (Pet.), Attachment (Attach.) at 6 (also noting past suicidal behavior);

(2) an October 2021 administrative note stating "HIGH RISK FOR SUICIDE FLAG? Yes," id. at 8;

(3) an April 2021 case management record noting that he had put a box cutter to his wrist earlier that month and reported making that suicide gesture about 2 times a week, id. at 9 (stating that he regretted waking up each morning and thought about overdosing);

(4) a March 2021 crisis line note stating that Mr. Heller had suicidal ideation with a plan and means but no intent, id. at 12 (reporting that he had ideations of driving his car into another car); see id. at 11 (indicating that he was a moderate to low suicide risk);

2 Case: 24-3504 Page: 3 of 12 Filed: 11/21/2024

(5) a November 2020 crisis line note showing that the veteran was having a difficult time resisting suicidal thoughts and that he hears voices daily, id. at 14 (reporting that he had active daily suicidal ideations and that he last attempted suicide 3 years ago by overdose, and the note stating that he was a moderate to high risk for suicide);

(6) an October 2020 crisis line note showing that Mr. Heller was a moderate to high risk for suicide, id. at 15;

(7) a suicide prevention follow-up stating that in July 2020 he experienced daily suicidal ideation with an intent but no plan, id. at 17 (reporting that he engaged in cutting to feel better);

(8) a May 2020 crisis line note showing that he reports dreaming of suicide every day, id. at 19-20 (noting a moderate to low risk of suicide);

(9) a December 2019 crisis line note stating suicidal ideation without a plan or intent, citing his children as his only reason for living, id. at 21-22 (noting a moderate to low suicide risk); and

(10) a September 2019 crisis line note in which the veteran reported putting a knife to his throat and that he regularly self-harms with a box cutter, id. at 24-25 (assessing a moderate to low risk of suicide).

The Board did not think that this warranted AOD status. And so, the Board rejected each of Mr. Heller's motions for advancement with substantially the same conclusory response: "In your case, the[re] . . . is . . . insufficient supporting medical evidence to demonstrate that you have an illness so serious or grave in nature that advancement is warranted." Pet. Attach. at 26 (March 2022 Board letter), 45 (May 2023 Board letter), 49 (November 2023 Board letter), 53 (January 2024 Board letter). Each time, the Board said nothing more about why Mr.

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Bluebook (online)
Richard Heller v. Denis McDonough, Counsel Stack Legal Research, https://law.counselstack.com/opinion/richard-heller-v-denis-mcdonough-cavc-2024.