CAVC Case 98-1825: Psychiatric

CAVCReal U.S. Court of Appeals for Veterans Claims (CAVC) decision · October 24, 2000 · HOLDAWAY

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.

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Outcome
Affirmed / Granted
Decision Date
October 24, 2000
Judge
HOLDAWAY
Service Era
Not specified

Conditions Claimed

PsychiatricHipTDIU

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Issues on Appeal

PsychiatricHipTDIU

Why It Was Decided This Way

The appellant immediately filed a second NOD, but again did not address concerns, if any, that he had about any other SSA records he had not submitted with his claim.

In its June 1998 decision, the Board found that at the time of the August 1979 rating decision, there was no competent medical evidence of record which demonstrated that the appellant's chronic acquired paranoid schizophrenia was actively psychotic, that it was not until April 1994 that competent medical evidence was presented which indicated that the appellant was permanently and totally disabled from any kind of employment, and that the appellant's claim for entitlement to an increased rating for chronic acquired paranoid schizophrenia was received by VA on April 29, 1994.

Once a claimant has submitted a well-grounded claim, the Secretary has a duty to assist the claimant "in developing the facts pertinent to the claim.

August 1979 decision The appellant also asserts that VA's failure to obtain his SSA records in August 1979 constitutes a violation of VA's duty to assist, and therefore, there is CUE as to that decision.

1999), has muddied the previous bright line rule dealing with failures on the part of VA to fulfill its duty to assist, and in doing so, has created an issue of finality in certain cases which needs to be addressed.

CUE This Court has long held that a failure of a duty to assist does not rise to the level of CUE.

The Federal Circuit's holding in Hayre changed that by providing veterans a means by which to attack, though technically not considered collateral in nature, a "final" rating decision, by claiming that VA failed in its duty to assist, which, if demonstrated, serves to "vitiate the finality" of that particular rating decision.

The Court notes that the distinction between Hayre and this case is that Hayre addressed VA's violations of the duty to assist as it relates to the VARO's acquiring of service medical records, documents which the Court points out are under VA control, whereas the issue in the instant case is the acquisition of the veteran's SSA records, documents not only not under VA control, but also not clearly pertinent to the claim presented.

Authorities Cited

Caffrey v. BrownHayre v. WestHurd v. WestMasors v. DerwinskiSee Baldwin v. WestSee Gilbert v. DerwinskiSee Murincsak v. DerwinskiSee Russell v. PrincipiSimmons v. West

Regulations Cited (38 CFR / 38 USC)

38 CFR 3.40038 USC 5107 (a)38 USC 5107(a)38 USC 5110 (a)38 USC 7104(d)(1)38 USC 7266 (a)(1)

Denial Type

Duty To Assist|Cue

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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.