The appellant sought service connection for a neck disability in the legacy system, and the Board denied the claim in 2018. While that legacy appeal was pending at the Court, VA later granted service connection for a neck disability in the AMA system effective January 25, 2023. The Secretary initially argued that the AMA grant mooted the legacy appeal, but later conceded the appeal remained live. The Court addressed the jurisdictional question because it presented an issue of continuing public interest in the interaction between legacy and AMA claim streams.

The Court held that the AMA grant did not moot the legacy appeal because the legacy claim could still provide an earlier effective date. The Court distinguished downstream effective-date principles and explained that mootness is case-specific. Where resolving the legacy appeal could affect the effective date and provide additional relief, the controversy remains live. On the merits, the Court found that the Board erred by failing to address direct service connection. Reading the pro se record sympathetically, the Court concluded that the veteran’s statements about neck and shoulder symptoms beginning together, and his confusion about the absence of neck complaints in service records, reasonably raised direct service connection. Because the Board did not analyze that theory, the Court could not find the error harmless and remanded for readjudication.

In an overlapping legacy and AMA posture, a grant of service connection in the AMA stream does not moot a pending legacy appeal when the legacy appeal may still yield an earlier effective date; and the Board must address a directly raised theory of service connection reasonably raised by the record.

Practitioners should not assume an AMA grant ends a parallel legacy appeal. If the legacy appeal can preserve an earlier effective date, it remains justiciable, and the Board must still adjudicate any reasonably raised direct service connection theory.

The decision provides clear guidance for common post-AMA jurisdiction problems involving parallel claim streams. It protects veterans from losing earlier effective-date opportunities simply because VA granted the benefit later in the AMA system, and it reinforces the Board’s duty to address theories reasonably raised by the record.

Treating an AMA grant as extinguishing a pending legacy appeal despite possible earlier-effective-date relief.

A veteran files a legacy service-connection appeal, later receives AMA service connection for the same disability effective from the later AMA claim date, and VA argues the legacy appeal is moot. Under this case, the legacy appeal may remain live if it could support an earlier effective date.

Use this case to oppose mootness arguments when a later AMA grant leaves earlier-effective-date relief available through a legacy appeal. It is also useful to argue that the Board must address direct service connection when a pro se veteran’s statements reasonably suggest that theory, even if the evidence was framed by VA as secondary service connection.