The appellant appealed the Board’s denial of service connection for ichthyosis vulgaris and arthritis of the knees and lumbosacral spine, increased ratings for traumatic arthritis of the right elbow, right shoulder, and neck, and eligibility for specially adapted housing. The Court affirmed the Board’s denial of service connection for arthritis of the knees and back, concluding that the Board’s causation findings were plausible and not clearly erroneous based on the evidence of record. It also affirmed the denial of specially adapted housing because the evidence did not show bilateral blindness or loss of use of two extremities.

The Court vacated and remanded the remaining issues. For the skin claim, the Court noted that the Secretary had moved for remand and that VA should have provided a medical examination to determine the nature and progression of any skin disorder in service and its relationship to current disability. For the rating issues, the Court held that the Board did not provide adequate reasons or bases when it translated medical range-of-motion findings into rating conclusions for the right elbow, right shoulder, and neck. The Board also should have addressed entitlement to TDIU in light of the combined 80 percent rating and the issues raised by the record. The case matters because it illustrates the Court’s demand for clear explanatory reasoning in rating decisions and its willingness to require development and consideration of reasonably raised claims.

The Board must provide an adequate statement of reasons or bases for translating medical evidence into rating determinations and must address reasonably raised theories such as TDIU; where the record suggests additional development is needed, VA’s duty to assist may require a medical examination.

Use this case to challenge rating decisions that summarize motion findings or disability severity without explaining how the evidence maps onto the rating criteria, and to argue that TDIU must be considered when the record reasonably raises unemployability.

Lineberger is an early Court decision emphasizing that the Board cannot simply announce rating outcomes without explaining key evidentiary and regulatory steps. It is especially helpful where the Board glosses over range-of-motion measurements, inconsistently describes examinations, or overlooks TDIU despite a substantial combined disability picture.

The Board failed to provide adequate reasons or bases for rating conclusions and failed to address a reasonably raised TDIU issue.

A veteran’s shoulder exam shows motion limited in one plane, but the Board denies a higher rating without explaining whether the rating criteria are satisfied by that limitation alone. The record also shows a high combined rating and evidence of work impairment, yet the Board never discusses unemployability.

Cite this case when seeking remand for inadequate reasons or bases in rating analysis, especially where the Board appears to have translated exam findings without explanation. It is also useful to argue that the Board must consider TDIU whenever the appeal record reasonably raises inability to secure or follow substantially gainful employment.

Gilbert v. Derwinski, EF v. Derwinski, Hatlestad v. Derwinski, Myers v. Derwinski, Payne v. Derwinski, Quarles v. Derwinski