CAVC Case 91-1665: Hip

CAVCReal U.S. Court of Appeals for Veterans Claims (CAVC) decision · March 30, 1995 · KRAMER

This is a decision of the U.S. Court of Appeals for Veterans Claims — the federal court that reviews Board of Veterans' Appeals decisions, one level above the Board. Court decisions can vacate, reverse, or affirm what the Board did.

What would this rating pay you? (2026 rates)

Official 2026 VA monthly compensation, including the 2.8% COLA increase.

per month ·  per year, tax-free

Dependent add-ons start at a 30% rating. Child-only and dependent-parent rates: see the full 2026 pay chart.

2026 base rates, all ratings (veteran alone)
RatingMonthly (2026, incl. 2.8% COLA)
10%$180.42
20%$356.66
30%$552.47
40%$795.84
50%$1,132.90
60%$1,435.02
70%$1,808.45
80%$2,102.15
90%$2,362.30
100%$3,938.58
See your full claim picture — free
Outcome
Vacated / Remanded
Decision Date
March 30, 1995
Judge
KRAMER
Service Era
Not specified

Conditions Claimed

HipHeadacheSkinEye

Sponsored
Missing the medical evidence for your VA claim? REE Medical connects veterans with independent licensed providers for nexus letters and DBQs — $50 off through this link.

Referral disclosure: VetAid earns a referral fee if you become a paying REE Medical client through this link — it helps keep this site free. REE Medical provides paid medical evidence; it is not a law firm, VSO, or claims agent, and VetAid has not independently verified its services. VSOs and VA-accredited representatives will help you file your claim at no cost, and no one can guarantee a rating increase.

Issues on Appeal

HipHeadacheSkinEye

Why It Was Decided This Way

The issue presented by this appeal is whether the Secretary's imposition by regulation of a causal nexus requirement, i.

Statutory Law The statute in effect when the appellant filed his claim for vocational rehabilitation in June 1989 did not require a causal nexus between a service-connected disability and an employment handicap.

) The issue before this Court is whether VA's imposition by regulation of a causal nexus, i.

Although earlier versions of the relevant statute did require a causal nexus between the service- connected disability and the employment handicap, see infra part III.

The language of the 1989 version, as well as that of the statute presently in effect, makes no reference whatsoever to such a nexus requirement.

The Secretary's Arguments As in Gardner, "[d]espite the absence from the statutory language of so much as a word about [a causal nexus], the Government proposes two interpretations in attempting to reveal a [causal nexus requirement] implicit in the text .

The first is that there is a "gap" in the statute which the Secretary is authorized to fill by regulation; the second is that § 3102 contains an implied causal nexus requirement.

The "Implied Causal Nexus" Argument This argument runs as follows: Because there are other statutes in chapter 31 that do contain express causal nexus requirements, it would lead to an "absurd result," and perhaps "raise concerns of fairness under the Constitution's Equal Protection Clause," if we refuse to infer such a requirement in § 3102.

Authorities Cited

Ad Hoc Committee v. United StatesBowsher v. SynarCentral Bank v. First Interstate BankClarke v. Securities IndustConroy v. AniskoffDarby v. CisnerosDavenport v. BrownGardner v. BrownGardner v. DerwinskiKing v. StMassachusetts v. MellonMistretta v. United StatesPauley v. BethRussello v. United StatesSkinner v. BrownSouth Carolina v. Katzenbach

Regulations Cited (38 CFR / 38 USC)

38 CFR 21.4038 CFR 21.40(a)(1)38 CFR 21.5138 CFR 21.51 (1993)38 CFR 21.51(b)38 CFR 21.51(c)38 CFR 21.51(c) (1994)38 CFR 21.51(c)(2)38 CFR 21.51(e)38 CFR 21.51(f)(2)38 CFR 21.51(f)(2) (1994)38 CFR 21.52(e)38 CFR 21.59 (1994)38 USC 1154(a)38 USC 150238 USC 1502 (1988)38 USC 3101(1)38 USC 3101(7)38 USC 310238 USC 3103(a)

Denial Type

No Nexus

Find Similar Precedent for Your Claim

VetAid's analyzer maps your claim against thousands of real Board of Veterans' Appeals decisions like this one — surfacing the exact case law that supports your arguments.

Run my claim through VetAid →
Sponsored
Missing the medical evidence for your VA claim? REE Medical connects veterans with independent licensed providers for nexus letters and DBQs — $50 off through this link.

Referral disclosure: VetAid earns a referral fee if you become a paying REE Medical client through this link — it helps keep this site free. REE Medical provides paid medical evidence; it is not a law firm, VSO, or claims agent, and VetAid has not independently verified its services. VSOs and VA-accredited representatives will help you file your claim at no cost, and no one can guarantee a rating increase.