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Board of Veterans' Appeals · Legacy series

Entitlement to a disability rating in excess of 10 percent for the Veteran's service-connected right knee disability is remanded.

January 30, 2026Citation Nr. 26001439Docket 18-50 101va.gov source

  • Entitlement to a disability rating in excess of 10 percent for the Veteran's service-connected right knee disabilityRemanded
DecisionAnalysis

Board reasoning

The Board remands for an updated VA examination to determine current severity, addressing active and passive range of motion with and without weight bearing, flare-ups and repeated use, and the ameliorative effects of medications. It must also consider lay reports of effusion and clicking and assess potential meniscal disability, plus provide a retrospective Correia-based opinion on functional loss since December 2015. The examiner should reconcile prior inadequate examinations and ensure all requested measurements are obtained and explained.

Issues

  • Entitlement to a disability rating in excess of 10 percent for the Veteran's service-connected right knee disabilityRemanded

Authorities

  • Bailey v. Wilkie, 33 Vet. App. 188Supports requirement to address secondary service connection claims reasonably raised
  • Wilson v. McDonough, 35 Vet. App. 103 (2022)Reiterates Bailey standard for raising related claims
  • Correia v. McDonald, 28 Vet. App. 158 (2016)Directs corrections for range-of-motion measurements in retroactive opinions
  • Ingram v. Collins, 38 Vet. App. 130 (2025)Addresses consideration of ameliorative effects of medication in functional loss

Extracted with gpt-5-nano-2025-08-07. Citations are kept only when they appear in the decision text.