Roberto Sanchez-Navarro sought service connection for PTSD based on stressors he described from service in Korea. The Board denied the claim, and the Veterans Court affirmed after concluding that the evidence was insufficient to corroborate the alleged stressors and that VA was not required to provide a psychiatric examination. While the appeal was pending, VA amended 38 C.F.R. § 3.304(f) to relax the evidentiary burden for certain PTSD claims involving fear of hostile military or terrorist activity.

The Federal Circuit held that the Veterans Court analyzed the claim under the general PTSD stressor rule rather than the specific framework in § 3.304(f)(3). The court explained that the regulation distinguishes between the psychiatrist or psychologist’s role in confirming that a stressor supports a PTSD diagnosis and the separate threshold question whether the claimed stressor is consistent with the places, types, and circumstances of service. Because the Veterans Court did not address that proviso, the Federal Circuit vacated and remanded for the proper regulatory analysis. The court also concluded that, if the proviso is satisfied, a VA psychiatric examination may be necessary under 38 U.S.C. § 5103A(d).

For PTSD claims governed by 38 C.F.R. § 3.304(f)(3), VA must separately determine whether the claimed stressor is consistent with the places, types, and circumstances of the veteran’s service; if that threshold is met, the veteran may be entitled to a VA psychiatric examination and the relaxed lay-testimony rule may apply.

The case is a useful reminder that PTSD claims involving fear of hostile military activity cannot be denied under the general stressor-corroboration standard without first analyzing whether § 3.304(f)(3) applies.

This case reinforces that PTSD stressor analysis is regulation-specific and that the agency must apply the correct evidentiary framework. In practice, it helps prevent premature denial where a veteran’s account may fit the relaxed PTSD rule but the Board or Veterans Court evaluates the claim under the stricter general corroboration standard.

Applying the general PTSD corroboration standard instead of analyzing the claim under 38 C.F.R. § 3.304(f)(3).

A veteran who served in a hostile environment reports fear-based stressors that are consistent with the circumstances of service, but the Board denies the claim because there is no independent corroboration of the stressor and does not address § 3.304(f)(3).

Use this case to argue remand when VA fails to identify and apply the correct PTSD stressor framework, especially where the record raises fear of hostile military activity and the Board relies on corroboration analysis alone.

38 C.F.R. § 3.304(f)(3), 38 U.S.C. § 5103A(d), 38 U.S.C. § 7292(a)