Mayfield v. Nicholson

Etsy Mayfield was a World War II veteran who was awarded a service-connected disability for a left-leg injury and varicosities in both legs. Following his death in 1999, his widow, Lizzie Mayfield (plaintiff) filed a claim for benefits with the Department of Veterans Affairs (the VA) (defendant), alleged that her husband’s death was service connected. The VA denied her claim, and Mrs. Mayfield appealed to the Board of Veterans’ Appeals (the board). In the meantime, Congress passed the Veterans Claims Assistance Act (VCAA) to provide support and ensure fairness for veterans in the claims-adjudication process. The board remanded Mrs. Mayfield’s claim for the VA to comply with new notice requirements contained in the VCAA. The VA sent a letter to Mrs. Mayfield that satisfied some of the notice requirements and eventually again denied her claim. Mrs. Mayfield again appealed to the board. The board upheld the denial and also held that the VA had complied with the new notice requirements. The board based this determination on other documents that the VA had sent Mrs. Mayfield following decisions in the case, not on the letter that was sent after remand. Mrs. Mayfield appealed the board’s decision to the United States Court of Appeals for Veterans Claims (the veterans court), including the issue of sufficient notice under the VCAA. The veterans court upheld the board’s decision but found that the notice requirement had been satisfied by the letter the VA had sent after remand, not by the other communications that were relied on by the board’s decision. Mrs. Mayfield appealed.