{"page":"https://casescribe.ai/explorer/secondary/migraine-secondary-to-hypertension","generated_at":"2026-10-03T18:34:27.887Z","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 hypertension","secondary_condition":"Migraine","service_connected_disability":"hypertension","decisions":374,"years":"2017-2026","granted_pct":23,"denied_pct":14.7,"remanded_pct":59.6,"granted_on_merits_pct":61,"by_year":[{"year":2018,"issues":22,"granted_pct":18.2,"denied_pct":13.6,"remanded_pct":45.5},{"year":2019,"issues":41,"granted_pct":46.3,"denied_pct":7.3,"remanded_pct":46.3},{"year":2020,"issues":32,"granted_pct":28.1,"denied_pct":25,"remanded_pct":46.9},{"year":2021,"issues":41,"granted_pct":14.6,"denied_pct":22,"remanded_pct":61},{"year":2022,"issues":42,"granted_pct":16.7,"denied_pct":4.8,"remanded_pct":76.2},{"year":2023,"issues":36,"granted_pct":22.2,"denied_pct":11.1,"remanded_pct":66.7},{"year":2024,"issues":56,"granted_pct":17.9,"denied_pct":10.7,"remanded_pct":69.6},{"year":2025,"issues":63,"granted_pct":28.6,"denied_pct":20.6,"remanded_pct":50.8},{"year":2026,"issues":23,"granted_pct":13,"denied_pct":17.4,"remanded_pct":65.2}],"benefit_of_doubt_in_grants_pct":67.4,"evidence_on_merits":[{"evidence":"va_exam_favorable","decisions_with":54,"granted_pct_with":90,"granted_pct_without":49.5},{"evidence":"va_exam_unfavorable","decisions_with":300,"granted_pct_with":57.3,"granted_pct_without":79.2},{"evidence":"nexus_positive","decisions_with":77,"granted_pct_with":88.7,"granted_pct_without":44.3},{"evidence":"nexus_negative","decisions_with":234,"granted_pct_with":57.7,"granted_pct_without":68.2},{"evidence":"private_opinion","decisions_with":119,"granted_pct_with":80,"granted_pct_without":48.8},{"evidence":"lay_statement","decisions_with":295,"granted_pct_with":56.1,"granted_pct_without":81.5}],"top_reasons":{"granted":[{"reason":"caused by the service-connected disability","decisions":22},{"reason":"current diagnosis established","decisions":10},{"reason":"service connection established","decisions":7},{"reason":"aggravated by the service-connected disability","decisions":6},{"reason":"criteria for secondary service connection met","decisions":3},{"reason":"conflicting medical opinions","decisions":2}],"denied":[{"reason":"va examiner: less likely than not related to service","decisions":10},{"reason":"preponderance of the evidence against the claim","decisions":5},{"reason":"aggravated by the service-connected disability","decisions":4},{"reason":"no current diagnosis","decisions":4},{"reason":"no in-service complaints, treatment or diagnosis","decisions":4},{"reason":"continuity of symptomatology since service","decisions":2}]},"recent_examples":{"granted":[{"case_id":"A26038382","year":2026,"judge":"RAY BARTO SLABBEKORN, JR.","rationale":"Criteria met for entitlement to service connection for headaches, secondary to stroke, sleep apnea and hypertension.; Veteran's headaches were caused by his service-connected stroke, sleep apnea and hypertension.; Benefit of the doubt afforded to the Veteran."},{"case_id":"A26016963","year":2026,"judge":"A. J. SPECTOR","rationale":"VA examiner considered Veteran's medical history including hypertension care management records.; Hypertension and diabetes mellitus can cause headaches due to blood pressure and blood sugar fluctuations.; Resolving reasonable doubt in Veteran's favor due to relative equipoise."},{"case_id":"26001374","year":2026,"judge":"JONATHAN B. KRAMER","rationale":"Evidence in approximate balance.; Benefit of doubt resolved in Veteran's favor.; Headaches attributed to hypertension by medical opinions."}],"denied":[{"case_id":"A26036397","year":2026,"judge":"LUKE PELICAN","rationale":"No medical diagnosis for headaches; No objective findings on examination; No medical evidence or history to substantiate complaints; No medical literature supports link between hypertension and headaches; Symptoms described as mild and unsubstantiated"},{"case_id":"A26033602","year":2026,"judge":"D. JOHNSON","rationale":"Service treatment records silent for headache complaints.; Private medical records silent for headache complaints.; VA examiner opined less likely than not related to or aggravated by hypertension.; Board found VA examiner's opinion probative and persuasive.; Medical literature did not demonstrate c… [truncated, 177 chars omitted]"},{"case_id":"26003992","year":2026,"judge":"RYAN T. KESSEL","rationale":"VA examiners opined less likely than not service-related.; Lack of in-service complaints and post-service risk factors noted.; Veteran's lay opinion inadequate to rebut examiner findings.; Claim as secondary to hypertension denied due to lack of service connection for hypertension."}]},"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":375,"aggravation_discussed":{"issues":143,"granted_pct":17.5},"causation_only":{"issues":232,"granted_pct":26.3},"issues_naming_a_pathway_pct":5.3,"pathways":[]},"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."}}