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Board of Veterans' Appeals · Legacy series

Entitlement to service connection for a left shoulder disability, to include as secondary to a service-connected disability, is denied.

January 30, 2026Citation Nr. 26001446Docket 19-22 447va.gov source

  • left shoulder disabilityDenied
  • lumbar spine disabilityDenied

Board reasoning

The Board concluded that the Veteran’s left shoulder and lumbar spine disabilities are not etiologically related to service nor caused or aggravated by a service-connected condition. Relying on recent addendum opinions, the Board found no objective evidence in service records of these conditions, and determined post-service development and medical literature did not support service causation or secondary causation. The lay assertions of in-service onset and continuity were deemed not persuasive given the lack of contemporaneous treatment and inconsistencies with reserve records.

Issues

  • left shoulder disabilityDenied
  • lumbar spine disabilityDenied

Authorities

  • Barr v. Nicholson, 21 Vet. App. 303 (2007)board found opinions probative and supported by evidence and literature
  • Stefl v. Nicholson, 21 Vet. App. 120 (2007)reliability of medical opinions
  • Nieves-Rodriguez v. Peake, 22 Vet. App. 295 (2008)medical opinion evaluation standard
  • Maxson v. West, 12 Vet. App. 453consideration of treatment history over time
  • Walker v. Shinseki, 708 F.3d 1331service connection requirements three criteria

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