CAVC Case 98-354: Depression

CAVCReal U.S. Court of Appeals for Veterans Claims (CAVC) decision · May 12, 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
Reversed
Decision Date
May 12, 2000
Judge
HOLDAWAY
Service Era
Not specified

Conditions Claimed

DepressionAnxietyPsychiatricBackSkinEyeArthritis

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Issues on Appeal

DepressionAnxietyPsychiatricBackSkinEyeArthritis

Why It Was Decided This Way

In the January 1998 BVA decision here on appeal, the Board denied the veteran's claim for CUE in the April 1977 RO decision.

§ 5110(i) (when previously disallowed claim is reopened and allowed on basis of new and material evidence in form of service department records, effective date is date such disallowed claim was filed).

309(a) [(1976)] [sic] had been met constituted a breach of its duty to assist", and that "[u]nder Hayre[, supra], the appellant's 1977 claim to entitlement to service[-]connected arthritis should be considered unadjudicated or nonfinal.

at 1335 ("if the Court of Appeals for Veterans Claims finds that the RO breached the duty to assist in 1972, then the 1972 RO decision is not final for purposes of direct appeal").

3d at 1331-34 (although the opinion recognized that a specific request for VA to obtain particular records may not be required in all circumstances in order for the duty to assist to be triggered); id.

at 1331 ("duty to assist may arise when a claimant simply refers to the pertinent private medical examinations or treatments without making a specific request").

Given the Federal Circuit's emphasis in Hayre on the need for VA to respond to assistance that was "specifically requested", on the fair "notice" aspect, and on the particular importance of SMRs, the Court concludes that Hayre does not require that a breach of the duty to assist such as is alleged in this case (failure to carry out, sua sponte, a VA examination) be considered such a grave procedural error as to have tolled the finality of the April 1977 RO decision.

We reach this conclusion on the assumption, but do not decide because we need not, that in April 1977 there was a well-grounded-claim requirement; that satisfying any such requirement was then a prerequisite to the triggering of a duty to assist; and that the RO in April 1977 had been presented with a well-grounded claim, see Hayre, 188 F.

Authorities Cited

Bustos v. WestCaffrey v. BrownChristianson v. Colt IndusDamrel v. BrownFugo v. BrownGodwin v. DerwinskiHauck v. BrownHayre v. WestIn Russell v. PrincipiPrenzler v. DerwinskiSee Crippen v. BrownSee Eddy v. BrownSkinner v. DerwinskiTablazon v. BrownTetro v. WestVelez v. West

Regulations Cited (38 CFR / 38 USC)

38 CFR 3.105(a)38 CFR 3.105(a) (1999)38 CFR 3.307(a)38 CFR 3.307(a) (1976)38 CFR 3.307(a)(3)38 CFR 3.309(a)38 CFR 3.309(a) (1976)38 USC 510838 USC 510938 USC 5110(i)38 USC 7104(d)(1)38 USC 725138 USC 7252(a)38 USC 7261(a)(3)

Denial Type

Not New Material|Duty To Assist|Cue

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