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Sellers v. Wilkie

965 F.3d 1328 (2020)

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Sellers v. Wilkie

United States Court of Appeals for the Federal Circuit
965 F.3d 1328 (2020)

SH

Facts

Robert M. Sellers (plaintiff) served in the US Navy and the US Army. In 1996, Sellers filed a claim with the Department of Veterans Affairs (VA) (defendant) for service-connected disability. The claim specifically described leg, knee, back, finger, and ear injuries. Sellers was granted service connection. While evaluating the claim, the VA obtained Seller’s medical records, which also contained information about Seller’s treatment for a psychological condition. In 2009, Sellers submitted an informal claim and was granted service-connected disability for major depressive disorder (MDD) with an effective date of 2009. Sellers appealed the effective date, claiming it should be dated back to the original application in 1996 because that filing was labeled as a request for service connection for “disabilities occurring during active duty service,” which, along with the medical records that the VA had obtained, implicitly included MDD. The Court of Appeals for Veterans Claims (Veteran’s Court) found in favor of Sellers, holding that a general statement of a veteran’s intent to seek benefits for unspecified disabilities might constitute a formal claim if a compensable condition is reasonably identifiable from the veteran’s medical-records claim record. The VA appealed.

Rule of Law

Issue

Holding and Reasoning (Clevenger, J.)

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