The appellant sought a total disability rating based on individual unemployability after the Board denied the claim. Although the Secretary conceded that the veteran was currently unemployable, the Board had not adequately explained why the veteran’s service-connected disabilities alone did not satisfy the TDIU standard. The Court held that the Board’s decision failed to satisfy 38 U.S.C. § 7104(d)(1) because it offered only conclusory findings, did not meaningfully address the relationship between service-connected and nonservice-connected disabilities, omitted discussion of several service-connected conditions, and failed to consider 38 C.F.R. § 4.18 regarding sheltered or accommodated employment. The Court vacated the decision and remanded for readjudication with an adequate statement of reasons or bases and proper application of the governing TDIU standard.

In adjudicating TDIU, VA must determine whether service-connected disabilities alone render the veteran unable to secure or follow substantially gainful employment, without regard to age or nonservice-connected disabilities, and the Board must provide an adequate statement of reasons or bases for that determination.

Pratt requires a real, disability-specific TDIU analysis, not a conclusory denial. It is especially useful when the Board ignores some service-connected disabilities, relies on age or nonservice-connected impairments, or fails to explain why accommodated work was still substantially gainful.

Pratt is an early and important TDIU reasons-or-bases decision. It clarifies that the Board must isolate the effect of service-connected disabilities and explain its reasoning in a way that allows judicial review, which remains a frequent point of appellate challenge in TDIU cases.

Inadequate Reasons or Bases [Procedural Error]

A veteran with multiple service-connected disabilities is denied TDIU because the Board emphasizes age, heart disease, or other nonservice-connected limitations, but the decision does not explain whether the service-connected conditions alone would prevent substantially gainful employment.

Cite Pratt to argue that the Board must analyze all service-connected disabilities, disregard age and nonservice-connected conditions, address sheltered or special employment, and provide a reviewable explanation for its TDIU conclusion.

Fluharty v. Derwinski, Hyder v. Derwinski, Hatlestad v. Derwinski, Mingo v. Derwinski, Goodman v. Derwinski, Fletcher v. Derwinski