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Board of Veterans' Appeals · Legacy series

Entitlement to service connection for a hair loss condition is granted.

January 30, 2026Citation Nr. 26001369Docket 06-26 131va.gov source

  • service connection for a hair loss conditionGranted

Board reasoning

The Board found that the veteran has a current hair loss condition that began in 1973 during service, supported by service treatment records showing treatment for hair loss and the veteran's consistent reports of ongoing symptoms. Although the May 2025 VA medical opinion leaned against radiation exposure as causative, the Board resolved reasonable doubt in the veteran's favor and concluded the evidence is at least in approximate balance as to in-service onset, granting service connection.

Authorities

  • Shedden v. Principi, 381 F.3d 1163Cited for requirements of substantiating a service-connection claim.
  • Jandreau v. Nicholson, 492 F.3d 1372Cited for competence to observe lay symptoms.
Citation Nr: 26001369 Decision Date: 01/30/26 Archive Date: 01/30/26 DOCKET NO. 06-26 131 DATE: January 30, 2026 ORDER Entitlement to service connection for a hair loss condition is granted. FINDING OF FACT After resolving all reasonable doubts in favor of the Veteran, the evidence is at least in approximate balance as to whether his current hair loss condition began during or as a result of his active service. CONCLUSION OF LAW The criteria for entitlement to service connection for a hair loss condition have been met. 38 U.S.C. § 1110; 38 C.F.R. §§ 3.303, 3.304, 3.309. REASONS AND BASES FOR FINDING AND CONCLUSION The Veteran had active military service from February 1972 to January 1975. This case has a lengthy procedural history. It is originally on appeal from a September 1997 rating decision by a Department of Veterans Affairs (VA) Regional Office (RO), which is the Agency of Original Jurisdiction (AOJ). The Veteran appealed his claim for service connection for hair loss to the Board of Veterans' Appeals (Board). The Board has remanded this issue several times, and it most recently remanded the claim in May 2020. The appeal is now before the Board once again. 1. Entitlement to service connection for hair loss The Veteran asserts that he experiences a current hair loss condition that began during or as a result of his active service. Service connection is warranted for a disability due to a disease or injury incurred in or aggravated by active service. 38 U.S.C. § 1110; 38 C.F.R. § 3.303. To substantiate a claim of service connection there must be competent evidence showing: (1) the existence of a claimed disability; (2) incurrence or aggravation of a disease or injury in active service; and (3) a causal relationship between the present claimed disability and the disease or injury incurred or aggravated during active service. Shedden v. Principi, 381 F.3d 1163, 1167 (Fed. Cir. 2004). In this case, the Veteran's primary etiological theory is that his claimed hair loss was caused by in-service exposure to radiation. Although there is insufficient evidence to support that theory, the Board finds that after resolving all reasonable doubts in favor of the Veteran, the evidence of record is in approximate balance as to whether his current diagnosed hair loss condition began during active service. The Veteran's service treatment records (STRs) reflect treatment for hair loss in March 1973, which had been occurring for six months. During the Veteran's most recent VA examination for the current condition, a May 2025 VA examination for skin conditions, the VA examiner noted that he was positive for a current diagnosis for traction alopecia. The examiner indicated that his traction alopecia began in 1973. In an accompanying VA medical opinion, the VA examiner found his hair loss was less likely than not related to in-service Toxic Exposure Risk Activity (TERA) and claimed radiation exposure. Instead, it was more likely due to years of wearing his hair in a ponytail and the effects of aging. The VA examiner did not explain how his traction alopecia began during service, when the Veteran would not have worn a ponytail or likely been affected by aging. Despite the limited medical reasoning provided in the May 2025 VA medical opinion, the Board finds that there is sufficient evidence to conclude that the VA examiner determined the Veteran had a current hair loss condition, and it began in 1973, during service. The Board notes that there are gaps in documented treatment for hair loss, and the Veteran did not file a claim for service connection until many years after separation from active service; however, his STRs reflect treatment for hair loss, and the Veteran has consistently asserted he has experienced hair loss since active service. In considering the Veteran's contentions, the Board notes that he is competent to observe lay symptoms such as hair loss. See Jandreau v. Nicholson, 492 F.3d 1372, 1377 (Fed. Cir. 2007). After resolving all reasonable doubts in favor of the Veteran, the Board finds the evidence of record is at least in approximate balance. The claim is accordingly granted. A. C. MACKENZIE Veterans Law Judge Board of Veterans' Appeals Attorney for the Board Hixon, Evan The Board's decision in this case is binding only with respect to the instant matter decided. This decision is not precedential and does not establish VA policies or interpretations of general applicability. 38 C.F.R. § 20.1303.