{"page":"https://casescribe.ai/explorer/secondary/migraine-secondary-to-neck","generated_at":"2026-10-03T18:34:23.227Z","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 neck (cervical spine) condition","secondary_condition":"Migraine","service_connected_disability":"a neck (cervical spine) condition","decisions":661,"years":"2017-2026","granted_pct":34.5,"denied_pct":12.1,"remanded_pct":52.3,"granted_on_merits_pct":74,"by_year":[{"year":2017,"issues":49,"granted_pct":28.6,"denied_pct":16.3,"remanded_pct":53.1},{"year":2018,"issues":49,"granted_pct":38.8,"denied_pct":12.2,"remanded_pct":46.9},{"year":2019,"issues":73,"granted_pct":27.4,"denied_pct":21.9,"remanded_pct":49.3},{"year":2020,"issues":77,"granted_pct":26,"denied_pct":11.7,"remanded_pct":62.3},{"year":2021,"issues":76,"granted_pct":30.3,"denied_pct":11.8,"remanded_pct":55.3},{"year":2022,"issues":63,"granted_pct":31.7,"denied_pct":12.7,"remanded_pct":54},{"year":2023,"issues":71,"granted_pct":39.4,"denied_pct":11.3,"remanded_pct":47.9},{"year":2024,"issues":101,"granted_pct":34.7,"denied_pct":5.9,"remanded_pct":57.4},{"year":2025,"issues":65,"granted_pct":44.6,"denied_pct":7.7,"remanded_pct":47.7},{"year":2026,"issues":41,"granted_pct":53.7,"denied_pct":12.2,"remanded_pct":34.1}],"benefit_of_doubt_in_grants_pct":75,"evidence_on_merits":[{"evidence":"va_exam_favorable","decisions_with":115,"granted_pct_with":92.6,"granted_pct_without":67.4},{"evidence":"va_exam_unfavorable","decisions_with":549,"granted_pct_with":71.9,"granted_pct_without":86.7},{"evidence":"nexus_positive","decisions_with":229,"granted_pct_with":94.7,"granted_pct_without":48.6},{"evidence":"nexus_negative","decisions_with":423,"granted_pct_with":70.1,"granted_pct_without":81.3},{"evidence":"private_opinion","decisions_with":299,"granted_pct_with":83,"granted_pct_without":61.1},{"evidence":"treating_physician","decisions_with":66,"granted_pct_with":85.7,"granted_pct_without":72.2},{"evidence":"lay_statement","decisions_with":550,"granted_pct_with":73.4,"granted_pct_without":77.8},{"evidence":"combat_service","decisions_with":41,"granted_pct_with":78.9,"granted_pct_without":73.7}],"top_reasons":{"granted":[{"reason":"caused by the service-connected disability","decisions":63},{"reason":"current diagnosis established","decisions":18},{"reason":"service connection established","decisions":13},{"reason":"aggravated by the service-connected disability","decisions":5},{"reason":"criteria for service connection met","decisions":5},{"reason":"secondary to cervical spine disability","decisions":3}],"denied":[{"reason":"no in-service complaints, treatment or diagnosis","decisions":12},{"reason":"va examiner: less likely than not related to service","decisions":5},{"reason":"aggravated by the service-connected disability","decisions":4},{"reason":"primary cervical spine condition not service-connected","decisions":4},{"reason":"preponderance of the evidence against the claim","decisions":4},{"reason":"caused by the service-connected disability","decisions":3}]},"recent_examples":{"granted":[{"case_id":"A26040926","year":2026,"judge":"ANTHONY C. SCIRÉ, JR","rationale":"Secondary service connection established; Related to active duty, environmental exposures, and/or cervical spine/nerve disabilities; Benefit of doubt resolved in Veteran's favor"},{"case_id":"A26040386","year":2026,"judge":"J.P. NORMAN","rationale":"Private ARNP opinion found more probative than VA examiner's opinion; VA examiner's opinion inadequate for failing to address aggravation; Evidence in equipoise, doubt resolved in veteran's favor"},{"case_id":"A26034527","year":2026,"judge":"JENNIFER WHITE","rationale":"Secondary to service-connected cervical spine disability; VA exam diagnosed tension headaches; Private opinion linked headaches to neck condition"}],"denied":[{"case_id":"26004679","year":2026,"judge":"PAUL SORISIO","rationale":"Primary cervical spine condition not service-connected.; Secondary claim denied as a matter of law.; Direct service connection for headaches not raised."},{"case_id":"A26034970","year":2026,"judge":"CHRISTOPHER SEPPANEN","rationale":"No current diagnosis of migraines found; Issue is medically complex, requiring specialized knowledge; Veteran not competent to diagnose migraines"},{"case_id":"A26023528","year":2026,"judge":"CYNTHIA M. BRUCE","rationale":"No known medical literature supports a causal relationship between migraines and cervical strain.; VA examiner's opinion found dispositive.; Evidence persuasively against the claim."}]},"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":665,"aggravation_discussed":{"issues":156,"granted_pct":14.7},"causation_only":{"issues":509,"granted_pct":40.7},"issues_naming_a_pathway_pct":3.9,"pathways":[{"pathway":"Nerve involvement","issues":18,"granted_pct":55.6,"examples":[{"case_id":"A26021340","year":2026,"outcome":"GRANTED","quote":"Secondary to service-connected neck and radiculopathy"},{"case_id":"A20010365","year":2020,"outcome":"DENIED","quote":"The Veteran claimed migraine headaches as secondary to cervical radiculopathy."}]}]},"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."}}