The veteran sought service connection for hypertension and related stroke residuals based on several elevated blood pressure readings in service. The Board found that the isolated elevated readings did not establish essential hypertension and that no medical evidence showed hypertension after service. The Court affirmed, explaining that service connection requires evidence of both a service-connected disease or injury and a current disability attributable to that disease or injury. The Court also noted that the hypertension rating schedule required at least the minimum compensable level, and the record contained no evidence of current hypertension. Because there was no current disability and no medical nexus linking the claimed stroke to hypertension, the claim was not well grounded. On that basis, the Court held that VA had no duty to assist, including no duty to provide an examination.

A claim for service connection must be supported by evidence of a current disability and a causal connection to service; without such evidence, the claim is not well grounded and VA has no duty to assist.

This case is a foundational citation for the current-disability element of service connection and for the former well-grounded-claim requirement. Practitioners should use it when the record shows in-service findings but no post-service diagnosis or competent nexus evidence.

Rabideau helps separate transient in-service findings from a compensable disability. It also illustrates the former jurisdictional effect of the well-grounded requirement: without a plausible claim, VA had no obligation to develop the evidence further.

Denying service connection without first identifying whether the evidence shows a current disability and competent nexus evidence.

A veteran points to elevated blood pressure readings in service but has no post-service diagnosis of hypertension and no medical opinion linking later symptoms to service. Rabideau supports a denial absent evidence of current disability.

Use Rabideau to emphasize that isolated abnormal findings are not enough by themselves. It is especially useful when challenging claims that rely on service records without a present diagnosis or competent linkage.

Gilbert v. Derwinski, Murphy v. Derwinski, Moore v. Derwinski