MacPhee v. Nicholson

459 F.3d 1323 (2006)

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MacPhee v. Nicholson

United States Court of Appeals for Veterans Claims
459 F.3d 1323 (2006)

CS

Facts

Patrick MacPhee (plaintiff) served in active duty from 1969 to 1972. In 1982, MacPhee was awarded a service-connected disability for posttraumatic stress disorder (PTSD) by the Department of Veterans Affairs (the VA) (defendant). In 1988, MacPhee was hospitalized in a VA medical center for alcoholism and anxiety. Treatment records from his hospitalization indicated that a VA psychologist believed that MacPhee’s alcohol abuse was related to his PTSD. In 1992, MacPhee sought and received an increase in his disability rating for his PTSD, which was eventually increased to 100 percent. In 1997, MacPhee claimed to be entitled to benefits for his alcoholism, alleging that his hospitalization medical records amounted to an informal claim for a service connection for his alcohol dependance. The VA denied his claim, and MacPhee appealed to the Board of Veterans’ Appeals (the board). The board upheld the VA’s denial, and MacPhee next appealed to the United States Court of Appeals for Veterans Claims (the veterans court). The veterans court affirmed the board’s decision, and MacPhee again appealed.

Rule of Law

Issue

Holding and Reasoning (Archer, J.)

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