The claimant sought a compensable rating for arthritis and limitation of motion in a fractured left little finger DIP joint. The Board denied a higher rating under the finger-specific diagnostic codes, and the Veterans Court affirmed, concluding that DC 5003 was not applicable because a DIP joint is not a major joint or a minor joint group for arthritis purposes. On appeal, the Federal Circuit exercised jurisdiction only to interpret the regulation, not to revisit the application of the regulation to the facts.

The court held that the plain language of DC 5003, read together with § 4.45(f), requires limitation of motion in more than one minor joint before the 10% arthritis rating for a “group of minor joints” applies. The court rejected the argument that a single affected interphalangeal joint can itself constitute a group of minor joints, explaining that the regulation refers to “multiple involvements” of interphalangeal joints. Because the court found no ambiguity, it declined to apply interpretive doubt in the veteran’s favor. The court therefore affirmed the Veterans Court’s interpretation and left any fact-specific application beyond its jurisdiction.

Under DC 5003 and 38 C.F.R. § 4.45(f), the 10% arthritis rating for a “group of minor joints” requires limitation of motion in more than one minor joint; a single interphalangeal joint is not enough.

DC 5003 cannot be used to obtain the 10% arthritis rating based on one isolated minor joint; the regulation requires multiple minor joint involvement.

Spicer gives VA and practitioners a clear interpretation rule for arthritis ratings involving fingers and other minor joints. It is especially important in cases where the claimant has noncompensable limitation of motion in only one interphalangeal joint and seeks the minimum arthritis rating under DC 5003.

Improper Interpretation of Regulation [Regulatory Interpretation Error]

A veteran has painful, noncompensable limitation of motion in one finger joint and argues that DC 5003 automatically entitles them to 10%. Under Spicer, that argument fails unless there is limitation of motion in more than one minor joint.

Use Spicer to oppose arguments that a single minor joint can be treated as a compensable joint group under DC 5003. It also helps frame appeals where the real issue is rating-criteria interpretation rather than factual weighing.

DC 5003, 38 C.F.R. § 4.45(f), Brown v. Gardner, Nielson v. Shinseki, Sursely v. Peake, Lockheed Corp. v. Widnall