The Court affirmed the Board’s denial of compensable ratings for shell fragment wound scars, holding that the Board’s factual finding was plausible, its reasons or bases were adequate, and the benefit-of-the-doubt rule was not violated.

The appellant sought compensable ratings for residuals of shell fragment wounds to the face and left ankle. The record contained VA examinations describing healed, nontender, nonadherent scars with no limitation of motion and no fracture or bony damage, while private physicians described numbness, neuritis, arthritis, pain, and difficulty walking. The Board weighed the evidence and found that the more recent private symptoms could not reasonably be attributed to the service-connected scar residuals given the essentially asymptomatic findings on VA examinations.

On appeal, the Court reiterated that Board factual findings are reviewed under the clearly erroneous standard and that rating determinations are factual. The Court held that there was a plausible basis in the record for the Board’s conclusion that the scars did not warrant an increased rating under Diagnostic Code 7804, which requires superficial scars to be tender and painful on objective demonstration. The Court also concluded that the Board satisfied the reasons-or-bases requirement and did not violate the benefit-of-the-doubt doctrine. The Board’s decision was therefore affirmed.

The Court vacated and remanded the Board’s denial of an increased PTSD rating so the claim could be readjudicated in light of Hood v. Brown.

The appellant sought an increased rating for service-connected post-traumatic stress disorder, then evaluated at 30 percent disabling. The Court did not reach the merits of the rating dispute; instead, it vacated the Board’s May 17, 1991 decision and remanded the matter for readjudication in light of Hood v. Brown. Because the opinion text provided is brief, the decision is best understood as a procedural remand tied to a then-recent change or clarification in PTSD rating analysis rather than a new merits holding. The practical effect was to require the Board to revisit the evaluation using the governing standard announced in Hood.

The Court affirmed a 50% PTSD rating because the veteran failed to show that VA applied the old schedular criteria after the 1988 revision; the record and SOC reflected use of the new, more favorable criteria.

The appellant sought a higher PTSD rating and argued that VA had effectively used the pre-1988 psychiatric rating criteria when assigning a 50% evaluation. The Court reviewed the June 1989 rating decision, the December 1989 Statement of the Case, and the Board’s reasons and bases. It concluded that the record supported the inference that VA applied the revised schedular criteria, which were in effect when service connection and the rating decision were made.

The Court also rejected the notion that the veteran’s own characterization of his symptoms as "severe" established entitlement to the higher rating. Although the Board did not expressly identify the revised regulation, its analysis tracked the language of the new criteria and satisfied 38 U.S.C. § 7104(d)(1). The Court further noted Karnas and recognized that the newer criteria were more favorable, but found no demonstrated legal or factual error warranting reversal. The decision was affirmed.

The Court summarily affirmed the Board’s denial of an increased rating for bronchiectasis, holding that the record supplied a plausible basis for the Board’s factual findings and that no clear error or reasons-and-bases deficiency was shown.

The veteran sought a rating higher than 30 percent for service-connected bronchiectasis with left lower lobectomy. The Board relied on the rating criteria under Diagnostic Code 6601 and medical evidence showing a minimal obstructive defect, normal lung volumes, and normal diffusing capacity, while also noting the absence of severe symptoms such as weight loss, anemia, pulmonary hemorrhage, or abundant expectoration. The veteran argued that his condition had worsened and caused early retirement, but the Court held that his testimony alone did not undermine the Board’s factual conclusions.

Applying the clearly erroneous standard and the deferential review described in Gilbert, the Court concluded that the Board had a plausible factual basis for denying a rating above 30 percent. The Court also stated that the Board satisfied the reasons-or-bases requirement and the benefit-of-the-doubt doctrine. The decision matters primarily as an early example of appellate deference to the Board’s weighing of medical and lay evidence in a rating case.

In Correia v. McDonald, the Court held that VA musculoskeletal examinations must comply with the testing requirements described in 38 C.F.R. § 4.59 when evaluating joint disabilities. The Court explained that, where possible, examinations should include range-of-motion testing for active motion, passive motion, weight-bearing, and non-weight-bearing conditions. The decision emphasized that inadequate orthopedic examinations may prevent accurate evaluation of functional loss and disability severity under the VA rating schedule.

The case held that joint examinations should, where possible, include testing for pain on active and passive motion and in weight-bearing and non-weight-bearing positions. In Correia v. McDonald, the Court clarified the examination requirements imposed by the final sentence of 38 C.F.R. § 4.59 in musculoskeletal disability claims involving joints. The veteran sought increased ratings for bilateral knee disabilities, arguing that the VA examinations relied upon by the Board were inadequate because they failed to include all required range-of-motion testing necessary to properly evaluate painful motion and functional impairment.

The Court examined the final sentence of § 4.59, which states that joints should be tested for pain on both active and passive motion, in weight-bearing and nonweight-bearing situations, and, if possible, with comparison to the opposite undamaged joint. The Court held that this testing is required whenever possible in cases involving joint disabilities because the regulation is intended to ensure that adjudicators have sufficient information to properly evaluate painful motion and functional loss.

The Court rejected the Secretary’s argument that the testing language in § 4.59 was merely optional or suggestive. Instead, the Court concluded that adequate VA joint examinations generally must include:

• active range-of-motion testing,
• passive range-of-motion testing,
• weight-bearing testing,
• nonweight-bearing testing,
• and explanation if such testing cannot be performed.

Because the examinations relied upon by the Board failed to include the required testing and did not explain why such testing could not be performed, the Court held that the Board clearly erred in finding the examinations adequate. The Board decision was vacated and remanded for a new examination and readjudication.

Correia became one of the foundational musculoskeletal examination cases in veterans law and remains central to disputes involving painful motion, range-of-motion testing, flare-ups, and functional loss under §§ 4.40, 4.45, and 4.59.

The Court vacated a PTSD rating denial because the Board failed to reconcile conflicting medical evidence, ignored materially favorable observations, and improperly refused a new examination despite a wide divergence in the record.

The veteran sought a rating higher than 30 percent for service-connected PTSD. The record contained multiple examinations and reports with different descriptions of severity and employability, including VA clinicians who noted improvement with treatment and a private psychologist who described severe chronic PTSD with severe work-related impairment. The Board denied an increase, emphasizing selected findings of orientation, logical thought, and memory, but did not meaningfully address the conflicting evidence or the private psychologist’s report. The Court held that the Board was required to thoroughly analyze and reconcile all relevant evidence and that its selective treatment of the record was inadequate. The Court also held that, given the wide divergence in the medical evidence, the Board’s refusal to order a complete psychoneurological examination violated the duty to assist. The decision was vacated and remanded for a new examination by different examiners with access to the relevant records.

The Court held that a former POW seeking presumptive service connection for traumatic arthritis or irritable bowel syndrome must show that the disease is disabling to at least a 10 percent level under the rating schedule. Because the record did not establish x-ray confirmed traumatic arthritis or bowel symptomatology meeting the compensable criteria for irritable bowel syndrome, the Board’s denial was affirmed.

The appellant, a World War II veteran and former prisoner of war, sought service connection for traumatic arthritis and irritable bowel syndrome based on POW presumptions. The Court reviewed the statutory and regulatory framework under 38 U.S.C. § 1112(b)(2) and 38 C.F.R. § 3.309(c), which provide presumptive service connection for certain POW diseases if they are manifest to a compensable degree. The Court then examined whether the evidence showed traumatic arthritis substantiated by x-ray findings and whether the bowel symptoms met the criteria for a 10 percent rating under Diagnostic Code 7319. The Court concluded that the hand x-ray did not confirm arthritis, the spinal degenerative changes were not linked to traumatic arthritis, and the bowel symptoms did not establish frequent bowel disturbance with abdominal distress. Because the required compensable level was not shown, the Court affirmed the Board’s denial of service connection.

In Cullen v. Shinseki, the Court addressed how VA evaluates spinal disabilities under the General Rating Formula for Diseases and Injuries of the Spine and clarified the relationship between orthopedic manifestations, neurologic abnormalities, and functional impairment. The decision examined whether separate evaluations may be assigned for distinct manifestations associated with a spinal condition and emphasized that VA must properly apply the rating criteria and adequately explain its evaluation of the veteran’s overall disability picture.

The case held that VA rates orthopedic disability under the General Rating Formula as a single thoracolumbar or cervical unit and must avoid duplicating compensation for the same spinal manifestations. In Cullen v. Shinseki, the Court addressed whether a veteran may receive more than one disability rating for the same condition under the same diagnostic code. The veteran sought increased ratings for residuals of a shrapnel wound involving the right shoulder and back, and for degenerative joint disease of the thoracic spine.

The Court held that, within a particular diagnostic code, a claimant is not entitled to more than one disability rating for a single disability unless the regulation expressly provides otherwise. The Court rejected the argument that different symptoms within the same diagnostic code could each support separate ratings for the same underlying disability.

However, the Court also held that the Board failed to provide adequate reasons or bases for denying higher ratings. For the thoracic spine, the Board acknowledged pain, fatigue, weakness, lack of endurance, flare-ups, and additional limitation after repetitive use, but failed to explain how those functional limitations were accounted for in the assigned rating. For the shrapnel wound residuals, the Board failed to adequately address evidence showing right shoulder flexion limited to 60 degrees, which could support a higher rating.

The decision was vacated and remanded because the Board’s functional-loss analysis was conclusory and did not adequately explain how painful motion, weakness, fatigue, and additional limitation affected the proper disability ratings.

The Court held that VA failed its duty to assist and reasons-or-bases obligations on the PTSD, nervous disorder, ulcer, and shoulder claims, but affirmed the noncompensable otitis externa rating because the Board’s factual finding was plausible and any examination defect was harmless.

This appeal arose from a Board decision denying service connection for PTSD, gastric ulcer disease, and a right shoulder disability, and denying a compensable rating for otitis externa. The Court first corrected the Secretary’s premise that PTSD or nervous disorders were chronic diseases subject to presumptive service connection, then focused on the Board’s handling of the service-connection claims and the rating issue. For PTSD and the broader nervous-disorder claim, the Court held that the claim was well grounded and that VA had a duty to assist by attempting to verify reported Vietnam stressors and by obtaining identified private and VA treatment records. The Board also failed to address a reasonably raised generalized anxiety disorder claim and failed to make explicit credibility findings or provide adequate reasons and bases regarding lay statements describing an early post-service nervous breakdown.

The Court held that separately rated radiculopathy is not automatically part of a pending spine appeal once VA has separately adjudicated it; a new NOD is required to challenge the radiculopathy effective date or rating.

Mai De Hart appealed a Board decision addressing the ratings assigned for her lumbar spine disability. During the pendency of that long-running legacy appeal, the RO separately adjudicated bilateral lower extremity radiculopathy, granted secondary service connection, and assigned separate ratings and effective dates. The veteran did not file a notice of disagreement with the 2019 radiculopathy decision, but when the spine rating issue returned to the Board, the Board did not discuss whether the right leg radiculopathy effective date was before it.

The Court held that it was not. The majority explained that although VA must identify and compensate neurologic complications when they are raised, once those complications are separately adjudicated and rated, they assume their own adjudicative identity and are governed by the normal rules of appellate status. The Court distinguished Chavis as fact-specific and relied on Grantham and Jarrell for the principle that an NOD directed to an upstream issue does not place later-decided downstream matters into appellate status. The Court also rejected the analogy to TDIU and Bailey, emphasizing that those authorities concern claim construction and initial adjudication, not whether a separately decided issue remains on appeal. The Board therefore did not err by failing to address the radiculopathy effective date as part of the spine appeal.

The dissent argued that the majority effectively overruled Chavis and that the Board should have addressed radiculopathy or at least remanded for the Board to explain its jurisdiction and reasons or bases. The majority nevertheless affirmed the Board on the radiculopathy issue and noted that a CUE motion may remain available to seek an earlier effective date.

In DeLuca v. Brown, the Court held that VA must consider functional loss caused by pain, flare-ups, weakness, fatigability, and incoordination when evaluating musculoskeletal disabilities based on limitation of motion. The Court explained that orthopedic examinations must adequately portray the extent of functional impairment during repeated use and flare-ups rather than relying solely on measured range-of-motion findings. The decision became a foundational case governing how VA evaluates painful motion and functional impairment under 38 C.F.R. §§ 4.40 and 4.45.

The case held that joint ratings must account for functional loss from pain, weakness, fatigability, incoordination, and flare-ups, not just the mechanical range-of-motion number. In DeLuca v. Brown, the Court fundamentally reshaped how VA must evaluate musculoskeletal disabilities involving pain and functional impairment. The veteran sought an increased rating for a left shoulder disability that caused pain, flare-ups, weakness, restricted motion, and work impairment.

The Board denied a higher rating primarily by relying on measured range-of-motion findings under Diagnostic Code 5201. The Board concluded that the rating criteria for limitation of motion already contemplated pain and therefore additional consideration under 38 C.F.R. §§ 4.40 and 4.45 was unnecessary.

The Court rejected that analysis. It held that diagnostic codes based on limitation of motion do not subsume the functional-loss requirements contained in §§ 4.40 and 4.45. The Court explained that VA must separately evaluate whether pain, weakness, fatigability, incoordination, repetitive use, and flare-ups produce additional functional impairment beyond the measured range of motion recorded during an examination.

The Court further held that VA examinations must adequately portray functional loss during flare-ups and repeated use over time. If feasible, examiners should express that additional functional impairment in terms of additional loss of range of motion. The Court found the examination inadequate because it merely recorded motion measurements without meaningfully addressing functional loss caused by pain and flare-ups.

DeLuca became one of the foundational precedents governing orthopedic and musculoskeletal disability ratings in veterans law and remains central to nearly every functional-loss analysis involving joint disabilities.

The Court held that the Board’s failure to discuss 38 C.F.R. § 4.131 was not prejudicial because the veteran’s PTSD service connection was established many years after discharge, outside the regulation’s scope. The current rating had to be based on present disability severity, not a retroactive discharge-era evaluation.

The veteran sought review of a Board decision denying an increased PTSD rating and argued that the Court’s single-judge memorandum decision failed to address 38 C.F.R. § 4.131. The Court denied panel review. In the accompanying concurrence, Judge Steinberg explained that although the Secretary conceded remand might be appropriate because the Board had not expressly discussed § 4.131, the regulation did not actually aid the veteran on these facts. Section 4.131 provides a minimum 50% rating at discharge and a follow-up examination within six months when a mental disorder severe enough to justify discharge is shown, but only where service connection is otherwise established in connection with that discharge. Because the veteran’s PTSD service connection was not established until many years after his 1978 separation, the regulation did not govern the current evaluation. The Court therefore treated the rating question as one of present severity under the ordinary rating framework, and the Board’s failure to discuss § 4.131 was not prejudicial.

The Court held that DC 8004’s 30% minimum Parkinson’s rating is not replaced by separate compensable ratings under other diagnostic codes when additional ascertainable Parkinson’s manifestations remain uncompensated. The Court also remanded the PTSD rating issue for failure to address documented symptoms.

Gilbert Duran, a Vietnam veteran service-connected for Parkinson’s disease, challenged VA’s rating methodology after the Board replaced his DC 8004 minimum 30% Parkinson’s rating with separate compensable ratings for several manifestations under other diagnostic codes. The Board reasoned that once separate ratings exceeded 30%, the minimum Parkinson’s rating could be discontinued. The Court rejected that interpretation, holding that the regulation’s text, structure, and rating-scheme context require the minimum 30% rating to remain when there are additional ascertainable Parkinson’s manifestations that are not otherwise compensable under the schedule. The Court emphasized that the rating scheme aims to avoid both undercompensation and pyramiding, and that VA’s approach would leave remaining manifestations uncompensated. The Court reversed the discontinuance of the Parkinson’s minimum rating and remanded for further proceedings. The Court also vacated and remanded the PTSD rating portion because the Board failed to address certain symptoms documented in lay and medical evidence.

The Court affirmed the Board’s denial of increased ratings for sinusitis and hemorrhoids, holding that the Board had a plausible factual basis for its rating findings and that VA properly denied the claims after the veteran refused a necessary examination without good cause under 38 C.F.R. § 3.655.

The veteran sought increased ratings for service-connected sinusitis and hemorrhoids. The Board had remanded the matter for a current and comprehensive examination, but the veteran refused to report and had also left an earlier VA examination before completion. The Court held that the Board’s factual findings were not clearly erroneous, that VA had satisfied its duty to assist by ordering the examination, and that the veteran’s failure to report without good cause supported denial of the increased-rating claims under 38 C.F.R. § 3.655. The Court also stated that the Board’s decision satisfied reasons-or-bases requirements and the benefit-of-the-doubt rule. The case matters because it confirms that a claimant’s noncooperation can defeat an increased-rating claim when a current examination is necessary to establish entitlement.

The Court vacated and remanded both the secondary-service-connection claim and the pes planus rating because the record was too ambiguous to support final fact-finding, the Board gave inadequate reasons or bases, and VA failed to fully develop the medical evidence.

The veteran sought secondary service connection for a right knee disability claimed as due to service-connected bilateral pes planus, along with a rating above 10 percent for pes planus. The Court reviewed a mixed record containing a general surgeon’s equivocal findings, a podiatrist’s opinion linking knee symptoms to poor foot mechanics, and Board findings that discounted some symptoms as due to nonservice-connected foot changes. The Court held that the evidence was too ambiguous to support a final merits decision because it was unclear whether the knee condition existed as a distinct disability, what caused it, and whether all foot-related symptoms were attributable to service-connected pes planus. The Court also held that the Board inadequately explained its rating decision, improperly relied on its own medical judgment, and failed to address lay statements, the benefit-of-the-doubt standard, and the need for further development. The case was vacated and remanded for an independent medical examination and additional records development.

In Esteban v. Brown, the Court held that VA may assign separate disability ratings for different manifestations arising from the same injury so long as the symptomatology for each condition is distinct and non-overlapping. The decision clarified the application of the anti-pyramiding rule under 38 C.F.R. § 4.14 and explained that veterans are entitled to separate evaluations when different disabilities produce separate and identifiable manifestations. Esteban became a foundational case governing separate ratings and overlapping symptom analysis in VA disability compensation.

The case held that separate ratings are permitted when different manifestations are distinct and nonoverlapping, even if they arise from the same injury. In Esteban v. Brown, the Court clarified when veterans may receive separate disability ratings for different manifestations arising from the same injury. The veteran suffered facial injuries in an in-service motor vehicle accident that resulted in disfiguring scars, painful scars, and facial muscle damage affecting mastication.

The Board acknowledged that the veteran qualified for compensable evaluations under multiple diagnostic codes, including disfigurement under Diagnostic Code 7800, painful scars under Diagnostic Code 7804, and facial muscle injury affecting mastication under Diagnostic Code 5325. However, the Board refused to assign separate ratings, concluding that only one rating could be assigned because all symptoms arose from the same facial injury.

The Court reversed that analysis and held that separate ratings are permitted when the symptomatology for each condition is distinct and non-overlapping. The Court explained that the anti-pyramiding rule in 38 C.F.R. § 4.14 prohibits compensating the same symptom twice, but it does not prohibit separate ratings for separate manifestations arising from the same injury.

The Court found that the veteran’s symptomatology was entirely distinct:

• cosmetic disfigurement,
• painful scars,
• and facial muscle impairment affecting chewing.

Because none of those manifestations duplicated or overlapped with one another, the veteran was legally entitled to separate compensable ratings for each condition.

Esteban became one of the foundational anti-pyramiding and separate-rating cases in veterans law and remains central to determining when multiple ratings may be assigned for different manifestations of the same injury or disease process.

The Court held that pre-amendment DC 5201 does not reach shoulder internal rotation, but it remanded the left-knee and lichen planus issues because the Board failed to give adequate reasons or bases and to address potentially favorable evidence.

The Court reviewed a Board decision that denied higher ratings for a right shoulder disability, a left knee disability, and lichen planus. On the shoulder issue, the veteran argued that limited internal rotation could be rated under the pre-amendment version of Diagnostic Code 5201. The Court rejected that interpretation, reasoning that the structure of 38 C.F.R. § 4.71 and Plate I shows that DC 5201 was concerned with shoulder flexion and abduction, not rotation in the transverse plane. The Court therefore affirmed the denial of a higher shoulder rating.

The Court then addressed the left knee. Relying on Lyles and Walleman, it explained that VA may award separate knee ratings only when the manifestations supporting each evaluation are distinct and not already compensated. The Court rejected the veteran’s argument that pain at rest and pain on motion are separate manifestations that can support different ratings. Still, it set aside and remanded because the Board did not adequately explain the basis for the staged left-knee ratings, did not clearly identify which diagnostic code supported the pre-May 2013 award, and did not adequately explain whether limitation of extension and pain were already contemplated by the meniscal rating.

Finally, the Court remanded the lichen planus issue. It held that the Board failed to address potentially favorable evidence suggesting systemic therapy before February 8, 2016, and therefore provided inadequate reasons or bases for denying a higher staged rating. The decision is significant because it clarifies the scope of pre-amendment shoulder rating criteria, reinforces the anti-pyramiding limits on separate knee ratings, and underscores the Board’s obligation to discuss favorable evidence when assigning staged skin ratings.

Faust v. West is a foundational TDIU case defining “substantially gainful employment” under 38 C.F.R. § 4.16. The Court held that employment producing annual income above the poverty threshold generally constitutes substantially gainful employment regardless of the number of hours worked. The case also reinforced that VA rating reductions must be based on actual improvement in the veteran’s ability to function under the ordinary conditions of life and work.

Faust v. West involved a veteran whose 100% disability evaluation for PTSD based on unemployability was later reduced after evidence showed that he was operating a business and earning substantial income. The record reflected that the veteran had previously been granted a total rating based on inability to engage in substantially gainful employment under the TDIU framework. However, later financial evidence demonstrated earnings of approximately $48,000 in a single year through self-employment activities.

The Court addressed whether this employment constituted substantially gainful employment for purposes of TDIU and whether the Board properly upheld the rating reduction. In doing so, the Court discussed the meaning of substantially gainful employment under 38 C.F.R. § 4.16. The Court explained that substantially gainful employment generally means employment that provides annual income exceeding the poverty threshold for one person, regardless of the number of hours or days worked. The Court emphasized that actual income level, rather than merely the structure or flexibility of employment, is a major factor in determining whether employment is substantially gainful rather than marginal.

The Court ultimately affirmed the Board’s decision, finding that the veteran’s demonstrated earnings established actual employability and substantially gainful employment. The case became one of the foundational precedents defining substantially gainful employment in the TDIU context.

Faust also reinforced broader rating reduction principles. The Court reiterated that VA rating reductions must comply with general regulatory protections governing reductions, including consideration of the veteran’s ability to function under the ordinary conditions of life and work. Later cases frequently cite Faust for the principle that actual improvement in functional capacity must be demonstrated before a rating reduction is proper.

In Fenderson v. West, the Court held that appeals involving the initial assignment of a disability rating are distinct from claims for increased evaluations and may require consideration of “staged ratings.” The decision explained that VA may assign separate ratings for different periods when the evidence shows changes in the severity of a disability over time. Fenderson became a foundational case governing staged ratings, retrospective evaluation of symptoms, and the distinction between initial-rating appeals and increased-rating claims.

The case introduced staged ratings for initial ratings, allowing separate percentage levels for distinct periods when severity changed during the appeal window. In Fenderson v. West, the Court clarified the distinction between an appeal of an initial disability rating and a traditional increased-rating claim. The veteran appealed the initial ratings assigned after service connection was granted for migraine headaches and plantar fasciitis.

The Board treated the claims as ordinary increased-rating claims and relied primarily on the veteran’s current level of disability. The Court held that this was legally incorrect because appeals of initial ratings remain part of the original claim and require review of the disability throughout the entire period beginning with the effective date of service connection.

The Court formally recognized the concept of “staged ratings,” holding that separate ratings may be assigned for separate periods of time based on the facts found during the initial-rating period.

Applying that rule, the Court found substantial evidence that the veteran’s migraine headaches were more severe during earlier portions of the appeal period than later records reflected. The Board therefore erred by focusing primarily on the present level of disability rather than evaluating fluctuations over time.

The Court also held that the Board failed to adequately address functional loss and pain in evaluating the veteran’s plantar fasciitis. Although the Board referenced 38 C.F.R. §§ 4.40 and 4.45, it failed to meaningfully apply them to evidence showing activity-related pain and functional limitations.

Fenderson became the foundational case governing staged ratings in veterans law and remains critical in all appeals involving initial disability evaluations.

The Court reversed and remanded because the Board failed to address the veteran’s unrebutted evidence that pain limited motion in an arthritis rating claim. Painful motion under 38 C.F.R. § 4.59 must be considered, and the Board cannot ignore evidence of pain when deciding whether a compensable rating is warranted.

The appellant sought a compensable rating for service-connected rheumatoid arthritis. The Board denied the claim on the ground that recent examinations showed no objectively demonstrated significant limitation of motion, even though the veteran had complained of pain and the record contained evidence suggesting painful motion. The Court held that the Board could not simply ignore the veteran’s evidence of pain, especially where pain was the central issue in the rating analysis. The Court relied on 38 C.F.R. §§ 4.40 and 4.59 and emphasized that arthritis ratings must account for painful motion and that examinations should note observable manifestations of pain. Because the Board failed to address that evidence, the decision was reversed and remanded for readjudication consistent with the opinion. The case matters because it requires adjudicators to analyze pain evidence directly and, when the record is inadequate, to obtain an examination that properly addresses painful motion.