Groves v. Peake

James Groves (plaintiff) served in the United States Army on active duty from 1969 to 1972 and again from 1974 to 1979. During service in 1979, Groves had an acute psychotic episode and was diagnosed with paranoid schizophrenia. Upon his discharge a few months later, he was diagnosed with a personality disorder. Groves was hospitalized twice in 1981 and treated for paranoid schizophrenia and schizoaffective disorder. Groves filed a claim for a service-connection disability with the Department of Veterans Affairs (VA) (defendant). In 1982 the VA confirmed the diagnosis of paranoid schizophrenia but was apparently unable to find service records of Groves’s in-service diagnosis and denied his claim, holding that he had not established a service connection for his current condition. Groves’s psychiatric disability continued, and he petitioned the VA to reopen his claim in 2000. At that point, the VA found a service connection for Groves’s schizophrenia and granted him benefits, but only effective from 2000 onward, not retrospective benefits back to his original claim. Upon Groves’s appeals for an earlier effective date, the Board of Veterans’ Appeals (the board) upheld the VA’s ruling. The board’s ruling was then upheld by the United States Court of Appeals for Veterans Claims (the veterans court). Both courts held that there was no clear error in the VA’s 1982 denial of a service connection because there had been no medical evidence linking Groves’s in-service and post-service diagnoses of schizophrenia. Groves sought review by the United States Court of Appeals for the Federal Circuit.