{"page":"https://casescribe.ai/explorer/secondary/migraine-secondary-to-back","generated_at":"2026-10-03T18:34:21.748Z","data_as_of":{"decisions":944125,"first_year":2017,"last_year":2026,"latest_decision":"2026-04-30","cfr":"2026-10-01","m21":"2026-09-29"},"about":{"publisher":"CaseScribe AI (VA Law Explorer)","source":"Public Board of Veterans' Appeals decisions (appeals of VA decisions, not VA's first decisions), M21-1 Adjudication Procedures Manual, 38 CFR Parts 3 and 4.","method":"Outcomes are issue-level: each condition the Board decided in a decision counts once. Decision data is extracted by AI and can contain errors. Rates describe past appeals and do not predict any claim.","disclaimer":"For research only. CaseScribe AI is not a law firm and this is not legal advice. Verify figures against the source decisions and regulations.","attribution":"Cite as: VA Law Explorer, CaseScribe AI, with the page URL."},"data":{"claim":"Migraine secondary to a back condition","secondary_condition":"Migraine","service_connected_disability":"a back condition","decisions":364,"years":"2017-2026","granted_pct":18.4,"denied_pct":14,"remanded_pct":66.8,"granted_on_merits_pct":56.8,"by_year":[{"year":2017,"issues":23,"granted_pct":8.7,"denied_pct":34.8,"remanded_pct":52.2},{"year":2018,"issues":28,"granted_pct":7.1,"denied_pct":21.4,"remanded_pct":71.4},{"year":2019,"issues":61,"granted_pct":23,"denied_pct":19.7,"remanded_pct":55.7},{"year":2020,"issues":32,"granted_pct":21.9,"denied_pct":3.1,"remanded_pct":71.9},{"year":2021,"issues":31,"granted_pct":12.9,"denied_pct":12.9,"remanded_pct":74.2},{"year":2022,"issues":48,"granted_pct":16.7,"denied_pct":18.8,"remanded_pct":64.6},{"year":2023,"issues":39,"granted_pct":30.8,"denied_pct":7.7,"remanded_pct":61.5},{"year":2024,"issues":44,"granted_pct":15.9,"denied_pct":6.8,"remanded_pct":77.3},{"year":2025,"issues":46,"granted_pct":13,"denied_pct":8.7,"remanded_pct":78.3}],"benefit_of_doubt_in_grants_pct":76.1,"evidence_on_merits":[{"evidence":"va_exam_favorable","decisions_with":45,"granted_pct_with":77.8,"granted_pct_without":50.5},{"evidence":"va_exam_unfavorable","decisions_with":301,"granted_pct_with":53.1,"granted_pct_without":72.7},{"evidence":"nexus_positive","decisions_with":83,"granted_pct_with":92.6,"granted_pct_without":26.6},{"evidence":"nexus_negative","decisions_with":254,"granted_pct_with":53.5,"granted_pct_without":65.6},{"evidence":"private_opinion","decisions_with":127,"granted_pct_with":79.7,"granted_pct_without":29.6},{"evidence":"lay_statement","decisions_with":295,"granted_pct_with":55.4,"granted_pct_without":64.7}],"top_reasons":{"granted":[{"reason":"caused by the service-connected disability","decisions":10},{"reason":"current diagnosis established","decisions":9},{"reason":"aggravated by the service-connected disability","decisions":9},{"reason":"service connection established","decisions":4},{"reason":"evidence evenly balanced","decisions":2}],"denied":[{"reason":"va examiner: less likely than not related to service","decisions":8},{"reason":"preponderance of the evidence against the claim","decisions":6},{"reason":"aggravated by the service-connected disability","decisions":5},{"reason":"no in-service complaints, treatment or diagnosis","decisions":4},{"reason":"no direct service connection established","decisions":2},{"reason":"no current diagnosis","decisions":2}]},"recent_examples":{"granted":[{"case_id":"A26019357","year":2026,"judge":"S. MERRICK","rationale":"Approximate balance of evidence; Benefit of the doubt applied; Persuasive private treating physician opinions"},{"case_id":"A26008788","year":2026,"judge":"MICHAEL A. PAPPAS","rationale":"Competent evidence establishes current diagnosis of tension headaches.; Veteran is service-connected for back disabilities.; Conflicting medical opinions (VA negative, private positive) created approximate balance, resolved in Veteran's favor."},{"case_id":"A26008790","year":2026,"judge":"MICHAEL A. PAPPAS","rationale":"Service connection granted as secondary to service-connected back disabilities.; Conflicting medical opinions (negative VA, positive private) resulted in approximate balance.; Benefit of the doubt applied to grant service connection."}],"denied":[{"case_id":"A26008297","year":2026,"judge":"MICHAEL MARTIN","rationale":"No diagnosis of headaches during or after service; Unfavorable VA examiner opinion; Evidence persuasively weighs against claim"},{"case_id":"A25084263","year":2025,"judge":"J. NICHOLS","rationale":"No in-service complaints, diagnosis, or treatment for headaches.; Veteran's statements in 2003 and 2017-2020 denied headaches.; Evidence weighed against secondary connection to lumbosacral strain."},{"case_id":"25009862","year":2025,"judge":"M. C. WILSON","rationale":"August 2024 VA exam persuasive; No medical evidence linking headaches to herbicide exposure; Headaches unrelated to service-connected back disability"}]},"how_argued":{"note":"From keyword matches in each issue's AI summary and rationale, not the full decision. Only issues whose text names a medical link are counted under pathways; one issue can name several. A link named in a denial was often the argument the Board rejected.","issues":367,"aggravation_discussed":{"issues":174,"granted_pct":12.6},"causation_only":{"issues":193,"granted_pct":23.3},"issues_naming_a_pathway_pct":10.6,"pathways":[{"pathway":"Nerve involvement","issues":15,"granted_pct":40,"examples":[{"case_id":"23036133","year":2023,"outcome":"GRANTED","quote":"The veteran has a diagnosis of tension headaches, and a private physician opined that the service-connected thoracolumbar spine degenerative joint and disc disease and lumbar radiculopathy aided in the development of and permanently..."}]}]},"how_va_rates":{"citation":"38 CFR 4.124a","diagnostic_code":"8100","name":"Migraine","url":"https://www.ecfr.gov/current/title-38/section-4.124a","levels":[{"criteria":"With very frequent completely prostrating and prolonged attacks productive of severe economic inadaptability","rating":50},{"criteria":"With characteristic prostrating attacks occurring on an average once a month over last several months","rating":30},{"criteria":"With characteristic prostrating attacks averaging one in 2 months over last several months","rating":10},{"criteria":"With less frequent attacks","rating":0}],"notes":[]},"requirements":"38 CFR 3.310: a current diagnosis, a service-connected disability, and medical evidence that it caused (3.310(a)) or aggravated (3.310(b)) the condition."}}