The veteran sought service connection for PTSD based on alleged Vietnam and Cambodia stressors. The record contained multiple PTSD diagnoses, but VA denied the claim on the ground that the stressors were not verified. The Court held that the Board erred by failing to make a specific finding as to whether the veteran engaged in combat with the enemy, by conflating the combat inquiry with corroboration of stressors, and by not fulfilling the duty to assist after the ESG requested additional stressor information that VA never sought from the veteran. The Court explained that, if combat is established and the stressor is related to combat, credible lay testimony may establish the stressor; if not, service records or other corroborating evidence are required. The Court also clarified that mere service in a combat zone is not enough by itself to establish a PTSD stressor. The decision was vacated and remanded for readjudication under the proper framework.

For PTSD claims, VA must make an explicit combat determination; combat-related stressors may be established by satisfactory lay testimony consistent with service, but noncombat stressors require corroborating evidence, and VA must assist in obtaining available verification evidence.

Before denying PTSD for lack of verified stressors, VA must separate the combat question from corroboration and must help develop the record when additional stressor details are needed.

Zarycki supplies the basic analytic framework for PTSD stressor development and remains important whenever VA rejects PTSD because it says the stressor was not verified. It is especially useful on appeal where the Board failed to make explicit combat findings or did not pursue available corroboration evidence.

Treating lack of verified stressors as the end of the analysis without first making a specific combat finding and without fully assisting in stressor development.

A veteran with a PTSD diagnosis alleges mortar attacks and ambushes in Vietnam. VA denies the claim because the exact incidents are not confirmed, but does not decide whether the veteran engaged in combat or request additional identifying information after the records repository asks for it.

Use this case to argue that VA must first determine combat status, then apply the correct stressor standard, and must continue reasonable development when the record suggests additional corroboration may exist.

Murphy v. Derwinski, Gilbert v. Derwinski, Wood v. Derwinski, Hayes v. Brown, Swann v. Brown, Ascherl v. Brown