Buchanan v. Nicholson
United States Court of Appeals for the Federal Circuit
451 F.3d 1331 (2006)

- Written by Carolyn Strutton, JD
Facts
Donald Buchanan (plaintiff) served on active duty in the United States Army from 1973 to 1975. He first filed a claim for a service-connected psychiatric disorder in 1986. The Department of Veterans Affairs (VA) (defendant) denied his initial claim, and the Board of Veterans’ Appeals (the board) affirmed that denial. Buchanan again filed for benefits in 1992 and presented lay evidence from various individuals, including his former sergeant, attesting to the fact that his psychiatric symptoms began during his service or shortly thereafter. Buchanan’s claim moved procedurally between the board and the VA for a number of years, during which Buchanan received three VA medical examinations. These examinations found that Buchanan suffered from schizophrenia or psychosis and that although his symptoms may have begun during service, it was impossible to confirm such a finding because there was no contemporaneous medical evidence of a psychiatric condition. When the matter finally came back before the board in 2002, the board denied Buchanan’s claim, holding that the lay evidence was not credible because it was not supported by contemporaneous medical evidence. Buchanan appealed to the United States Court of Appeals for Veterans Claims, which affirmed the board’s decision. Buchanan again appealed.
Rule of Law
Issue
Holding and Reasoning (Prost, J.)
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