Brooks v. Brown — Myocardial infarction during inactive duty training is not an injury for service connection

Daniel H. Brooks sought service connection for heart disease after suffering a myocardial infarction while on inactive duty training. The Board denied the claim as not well grounded, relying on VA General Counsel precedent that a heart attack during inactive duty training does not qualify as an in-service injury for purposes of service connection. The Court affirmed, holding that the relevant statutes plainly distinguish between disease and injury and permit service connection for inactive duty training only when the disability results from an injury incurred or aggravated in line of duty. The Court also concluded that a myocardial infarction is a disease, not an injury, and therefore cannot support direct service connection on the facts presented. The Court further held that the Board’s reasons and bases were adequate and declined to consider a different heart-condition theory because it had not been properly presented to or exhausted before the agency.

For inactive duty training, 38 U.S.C. § 101(24) authorizes service connection only for disability resulting from injury, not disease; a myocardial infarction is a disease, not an injury.

When a reservist’s claim is based on inactive duty training, the threshold question is whether the event qualifies as an injury under the statute. If the condition is a disease process such as a myocardial infarction, direct service connection under the inactive-duty theory is unavailable.

Brooks remains a foundational case on the statutory line between injury and disease for reservists. It helps practitioners screen out legally unavailable theories early and focus development on other potentially viable bases, such as active duty for training, direct disease incurrence during qualifying service, or separate heart pathology if properly raised.

Misclassifying a disease process as an in-service injury for inactive duty training service connection.

A National Guard member has a heart attack while drilling on weekend inactive duty training and later seeks service connection based solely on that event. Under Brooks, that theory fails because the heart attack is not an injury under 38 U.S.C. § 101(24).

Use Brooks to challenge theories that rely on inactive duty training when the claimed disability is clearly a disease rather than an injury. It is also useful for framing whether the claimant actually raised a different heart-related theory that VA must separately adjudicate.

Murphy v. Derwinski, Tirpak v. Derwinski, Biggins v. Derwinski, Gardner v. Derwinski, Cole v. Derwinski