The claimant sought service connection for bilateral knee pain after the Board denied the claim under Sanchez-Benitez, reasoning that pain alone is not a disability absent a diagnosed or identifiable underlying condition. The Federal Circuit exercised jurisdiction to review the Veterans Court’s legal interpretation of 38 U.S.C. § 1110 and held that the term “disability” refers to functional impairment of earning capacity, not the underlying cause of that impairment. Because pain can itself cause functional impairment, the court concluded that pain may qualify as a disability even without a diagnosed pathology. The court emphasized, however, that subjective pain alone is not enough; the claimant must show that the pain rises to the level of functional impairment. The Federal Circuit reversed the legal ruling and remanded for the Board to determine whether the claimant’s knee pain met that standard and, if so, whether the remaining service-connection elements were satisfied.

For purposes of 38 U.S.C. § 1110, “disability” means functional impairment of earning capacity, and pain can satisfy that requirement if it causes such impairment even without a diagnosed underlying condition.

Saunders opened the door for veterans to prove a current disability through painful functional limitation, not just a formal diagnosis. It is especially useful where service-related pain limits work or daily functioning but medical providers cannot identify a specific pathology.

This case materially changed the law in the Federal Circuit by overruling the categorical no-pain-as-disability approach used by the Veterans Court. It is a leading authority for claims where the main evidence is persistent pain with functional loss, and it requires adjudicators to focus on impairment rather than diagnosis labels.

Treating pain as noncompensable solely because no underlying diagnosis has been identified.

A veteran has chronic knee pain after service, uses a brace, cannot stand for long periods, and misses work, but imaging does not reveal a specific structural diagnosis. Under Saunders, the veteran may still establish a current disability if the pain functionally impairs earning capacity.

Use Saunders to challenge denials that stop at the absence of a diagnosis. Build the record around functional impact, work limitations, daily activity restrictions, and examiner findings showing pain-related impairment.

Allen v. Brown, Sanchez-Benitez v. West, Sanchez-Benitez v. Principi, Shedden v. Principi, Joyner v. McDonald, Thompson v. McDonald