Arzio v. Shinseki — PTSD claims require credible supporting evidence of the in-service stressor under § 3.304(f)

Michael Arzio sought service connection for PTSD after previously being denied by VA. The record showed psychiatric-type symptoms during service, but the Board found that he had not provided credible supporting evidence that an in-service stressor actually occurred. Arzio argued that he could establish service connection under the general principles of 38 C.F.R. § 3.303 without meeting the PTSD-specific requirements of 38 C.F.R. § 3.304(f).

The Federal Circuit rejected that argument. The court explained that § 3.304(f) is the specific regulation governing PTSD claims and expressly requires medical evidence diagnosing PTSD, a medical nexus to an in-service stressor, and credible supporting evidence that the stressor occurred. The court held that § 3.303 states only general service-connection principles and does not provide an alternative method for avoiding § 3.304(f)’s specific evidentiary requirements. Applying the canon that the specific governs the general, the court affirmed the denial of benefits. The decision is important because it reinforces that PTSD claims must be proven under the PTSD-specific regulation, and general service-connection language cannot substitute for stressor corroboration.

For PTSD claims, 38 C.F.R. § 3.304(f) supplies the controlling requirements and mandates credible supporting evidence that the claimed in-service stressor occurred; 38 C.F.R. § 3.303 does not independently permit service connection without satisfying § 3.304(f).

Veterans and advocates cannot rely on general service-connection principles to bypass PTSD’s stressor corroboration requirement. If the claim is for PTSD, the stressor element must be addressed directly unless a regulatory exception applies.

Arzio is a clear Federal Circuit statement that PTSD is a specialized service-connection category with its own mandatory proof structure. It is useful when VA or a claimant tries to treat PTSD like an ordinary direct service-connection claim and skip the corroboration analysis required by § 3.304(f).

Improper Interpretation of Regulation [Regulatory Interpretation Error]

A veteran shows treatment records for anxiety and PTSD-like symptoms during service, but cannot verify the specific traumatic event alleged as the cause of current PTSD. Under Arzio, the claim may still fail because the stressor requirement in § 3.304(f) is mandatory.

Use Arzio to argue that adjudicators must apply § 3.304(f) as the governing PTSD standard and may not award PTSD service connection based solely on general direct-service-connection language in § 3.303.