Mauerhan v. Principi

Albert Mauerhan (plaintiff) was a Vietnam War combat veteran who suffered from posttraumatic stress disorder (PTSD). In 1988, Mauerhan filed a claim with the Department of Veterans Affairs (VA) (defendant) for a service-connected disability for his PTSD. Mauerhan suffered from intense anxiety, hypervigilance, insomnia, and social isolation and had attempted suicide three times. Mauerhan was in a long-term relationship and maintained contact with his children, however, and had held steady employment for a number of years, although he had conflicts with his colleagues. The VA determined that he was entitled to a 30 percent disability rating for his service-connected PTSD. Mauerhan sought a higher rating, but upon review the VA ruled that the 30 percent rating was appropriate. Mauerhan appealed to the Board of Veterans’ Appeals (the board). The board ruled that the 30 percent disability rating was appropriate because Mauerhan’s symptoms most closely aligned with that level of disability rating under the VA’s regulatory disability-ratings schedule for mental illnesses. Mauerhan appealed, alleging that the board had erred in relying only on the VA’s ratings categories rather than considering PTSD-specific criteria established by the American Psychiatric Association’s Diagnostic and Statistical Manual of Mental Disorders (DSM-IV).