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Board of Veterans' Appeals · Legacy series

Entitlement to service connection for hydrocephalus as secondary to service-connected Parkinson's disease is granted.

January 30, 2026Citation Nr. 26001466Docket 19-02 507va.gov source

  • Hydrocephalus as secondary to service-connected Parkinson's diseaseGranted

Board reasoning

The Board found that the Veteran's hydrocephalus was aggravated by his service-connected Parkinson's disease, resolving all doubt in his favor. It reasoned there is evidence of a current hydrocephalus disability separate from Parkinson's and that while the record does not clearly show which condition started first, the record supports aggravation by the Parkinson's disease, with no contrary medical opinion. The Board applied the benefit-of-the-doubt doctrine and determined secondary service connection is warranted.

Issues

  • Hydrocephalus as secondary to service-connected Parkinson's diseaseGranted

Authorities

  • Spicer v. McDonough, 61 F.4th 1360cited to discuss recent authority on aggravation in the secondary service connection context
  • Barr v. Nicholson, 21 Vet. App. 303cited regarding lay evidence and competency for diagnosis
  • Layno v. Brown, 6 Vet. App. 465cited regarding lay observation of symptoms
  • Jandreau v. Nicholson, 492 F.3d 1372cited on limitations of lay diagnosis for medical questions
  • Lynch v. McDonough, 21 F.4th 776cited for benefit-of-the-doubt framework when evidence is in approximate balance

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