Service connection for a right wrist disability is granted.

Citation Nr: 26001421 Decision Date: 01/30/26 Archive Date: 01/30/26 DOCKET NO. 14-17 109 DATE: January 30, 2026 ORDER Service connection for a right wrist disability is granted. Service connection for a left wrist disability is granted. FINDINGS OF FACT 1. Affording the Veteran the benefit of the doubt, his right wrist disability manifested during his active-duty service with continuity of symptomology since discharge. 2. Affording the Veteran the benefit of the doubt, his left wrist disability manifested during his active-duty service with continuity of symptomology since discharge. CONCLUSIONS OF LAW 1. The criteria for service connection for a right wrist disability have been met. 38 U.S.C. §§ 1110, 1111; 38 C.F.R. §§ 3.303, 3.304, 3.307, 3.309. 2. The criteria for service connection for a left wrist disability have been met. 38 U.S.C. §§ 1110, 1111; 38 C.F.R. §§ 3.303, 3.304, 3.307, 3.309. REASONS AND BASES FOR FINDINGS AND CONCLUSIONS The Veteran served on active duty from April 1978 to April 1982. He also had a period of active duty for training from June 1976 to October 1976. These matters are before the Board of Veterans' Appeals (Board) on appeal from an August 2010 rating decision of a Department of Veterans Affairs (VA) Regional Office (RO). Most recently, in September 2023, the Board remanded these issues. Service Connection Generally, service connection requires: (1) the existence of a present disability; (2) an in-service incurrence or aggravation of a disease or injury; and (3) a causal relationship between the present disability and the disease or injury incurred or aggravated during service, i.e., the so-called "nexus" requirement. See Holton v. Shinseki, 557 F.3d 1362, 1366 (Fed. Cir. 2009) (quoting Shedden v. Principi, 381 F.3d 1163, 1166-67 (Fed. Cir. 2004)). In certain cases, competent lay evidence may demonstrate the presence of any of these elements. See Davidson v. Shinseki, 581 F.3d 1313, 1316 (Fed. Cir. 2009). The nexus element may also be fulfilled by: (1) a nexus opinion or (2) competent and credible evidence showing the Veteran has experienced frequent and persistent symptoms of the disease since service. See 38 U.S.C. § 1154 (a); 38 C.F.R. §§ 3.303 (a), (d); see also Davidson, 581 F.3d 1313. Service connection can also be established through application of statutory presumptions including chronic diseases that become manifest to a compensable degree within one year of separation from service or when there is continuity of symptomology since separation of service. See 38 C.F.R. §§ 3.303 (b), 3.307, 3.309; Walker v. Shinseki, 708 F.3d 1331, 1338-39 (Fed. Cir. 2013). Additionally, service connection may be granted for any injury or disease diagnosed after discharge when all the evidence, including that pertinent to service, establishes the disease or injury was incurred in service. See 38 C.F.R. § 3.303 (d). Finally, the Board must determine whether the evidence persuasively favors the claim or if there is an approximate balance of positive and negative evidence (i.e., relative equipoise) regarding any issue material to the determination of a matter, with the Veteran prevailing in either event or whether the evidence persuasively weighs against the claim in which case it must be denied. See Lynch v. McDonough, 999 F.3d 1391 (Fed. Cir. 2021); Gilbert v. Derwinski, 1 Vet. App. 49, 53 (1990); see also 38 U.S.C. § 5107; 38 C.F.R. § 3.102. 1. Service connection for a right wrist disability is granted. 2. Service connection for a left wrist disability is granted. The Veteran contends service connection is warranted for a bilateral wrist disability. See May 2015 VA Form 9. Regarding a current diagnosis, the Board finds the Veteran's post-service treatment records reflect a pathology as to a bilateral wrist disability. The Board acknowledges an August 2016 VA wrist examination indicates the Veteran does not have a bilateral wrist condition apart from a left wrist strain from 1990; however, that same examination report documents initial range-of-motion measurements for both the right and left wrists to be abnormal or outside of a normal range. Further, the Veteran reported flare-ups of the bilateral wrists in the form of an increase in pain with activity. As to an in-service incident, the Veteran's service medical records reflect a bilateral wrist pathology. Regarding this, an October 1980 radiology report notes blunt trauma to the left wrist with reports of tingling and tenderness over the anterior portion of the mid-wrist. Further, a June 1978 radiology report notes an examination request for the right wrist after the Veteran fell off a truck. Another June 1978 service medical record notes complaints of pain in the right wrist after falling from the vehicle. Given the evidence of a current diagnosis and an in-service event, the evidence turns on whether there is a nexus between the Veteran's current bilateral wrist pathology and his active service. Upon review of the evidence of record, and resolving reasonable doubt in the Veteran's favor, the Board finds service connection for a bilateral wrist disability is warranted. Regarding this, post-service treatment records and lay statements reflect a bilateral wrist pathology since active service. For example, in a February 2010 VA 21-0820 Report of General Information, the Veteran reports he was seeking service connection for a disability of the bilateral wrists, and his pain and wrist problems began after a fall from a military vehicle during active service. Further, in February 1992, a physician diagnosed the Veteran with an old sprain of the right wrist with occasional symptoms. On examination, the physician notes the Veteran's "right wrist has essentially full motion compared to the left with soreness over the back of the distal radial ulnar joint [where] he had some swelling initially." In reaching their conclusions, the physician notes the Veteran's military history to include his documented fall from a truck within his service medical records. In January 1993, a VA treatment record notes the Veteran reported complaints of aching wrists, and the treatment report documents the Veteran's fall from the truck during active service. A diagnosis of "s/p fall from truck in the service & posttraumatic arthritis" was given. The record goes on to note, "Requests meds for arthritis pain to... [the] wrists esp. in cold weather." In May 2008, the Veteran reported complaints of pain in the bilateral wrists. On remand, VA received a nexus opinion in April 2024 as to the Veteran's bilateral wrists. For both wrists, the examiner states, "The veteran's wrist condition is more likely due to the fall noted in 1978 and 1980," which indicates a positive nexus opinion. However, VA obtained an addendum opinion in November 2024 from the same examiner, and they provide a negative nexus opinion. The examiner states the Veteran's diagnosed condition was less likely than not incurred in or caused by the right and left wrist conditions during active service. For their rationale, the examiner notes the Veteran's service medical records indicate he injured his wrists due to falls in 1978 and 1980. The examiner goes on to note the Veteran's records are silent for evidence to support his current bilateral wrist condition is a continuation from the bilateral wrist condition during active service. Finally, VA received an addendum opinion in May 2025. The examiner provides a negative nexus opinion, and they were unable to establish a chronicity of symptoms. The Board acknowledges the VA negative nexus opinions; however, the probative value of these opinions is reduced because the examiners do not directly address the indication of a continuity of symptoms since active service, which includes lay statements that the Veteran has had a bilateral wrist condition since active service in the form of bilateral wrist pain. The Board observes it is symptoms, not treatment, which are the essence of any evidence of continuity of symptomatology. Savage v. Gober, 10 Vet. App. 488, 496 (1997) (citing Wilson v. Derwinski, 2 Vet. App. 16, 19 (1991)). Accordingly, upon review of the evidence of record, the Board finds the repeated complaints and treatment for a bilateral wrist condition during service, the Veteran's lay statements as to a continuity of symptoms since service, the post-service diagnoses of a bilateral wrist condition or pathology, place the competent evidence of record at least in equipoise in favor of the claim. Therefore, resolving reasonable doubt in the Veteran's favor, service connection for a bilateral wrist disability is warranted. Thomas L. English Veterans Law Judge Board of Veterans' Appeals Attorney for the Board Buck Denton 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.