The veteran appealed a Board decision denying increased ratings for a thoracic spine fracture and right internal carotid artery occlusion, denying service connection for lightheadedness, vertigo, left leg numbness, and lumbar spine disability, and denying TDIU. The Court upheld the Board’s determinations on the service connection and rating issues, finding a plausible basis in the record and adequate reasons or bases. The Court then focused on the TDIU claim and held that the Board had not properly considered whether the veteran’s service-connected disabilities, considered both individually and in combination, prevented him from securing and following substantially gainful employment. Because the Board’s analysis was insufficient under the governing regulation and reasons-or-bases requirements, the Court vacated that portion of the decision and remanded for readjudication.

In adjudicating TDIU, VA must evaluate whether the veteran’s service-connected disabilities, considered individually and collectively, preclude substantially gainful employment; a noncompensable service-connected disability does not bar TDIU if the overall service-connected disability picture renders the veteran unemployable.

TDIU analysis cannot be limited to one condition or to compensable ratings; the Board must address the aggregate occupational impact of all service-connected disabilities.

The case is an early CAVC decision emphasizing that unemployability turns on functional work capacity, not on whether any single service-connected disability carries a compensable rating. It is useful when the record shows vocational rejection or employment difficulty tied to multiple service-connected conditions.

Failing to consider TDIU and the combined occupational impact of all service-connected disabilities.

A veteran with several service-connected conditions receives multiple low or noncompensable ratings, but employers repeatedly reject the veteran because the combined physical limitations prevent reliable work. The Board denies TDIU by analyzing only one disability; Hodges supports remand.

Use this case to argue that the Board must evaluate the combined effects of all service-connected disabilities on substantially gainful employment and provide an adequate reasons-or-bases discussion.

Gilbert v. Derwinski, Goodman v. Derwinski, Blackburn v. Brown, Fanning v. Brown, Moyer v. Derwinski