KNEE IMPAIRMENT OF

Summary

The veteran, an Army veteran who served from August 1989 to May 1992, appeals the denial of service connection for bilateral knee disabilities, claimed as secondary to his service-connected pes planus with plantar fasciitis. The veteran's service treatment records and separation examination did not document any knee complaints or treatment. However, the veteran reported knee pain starting in the 1990s and was diagnosed with left knee arthritis in 2017. VA examinations in 2018 and 2019 found the knee conditions less likely than not related to or aggravated by the service-connected foot condition, citing a lack of in-service complaints and medical literature not supporting a link. The veteran's testimony in a 2021 hearing claimed in-service knee pain and being placed on profile due to knees, but this was contradicted by service records and separation exams. A 2022 VA examination again found no in-service event and negative nexus, noting the first documentation of knee problems was 25 years post-service. A 2025 VA examination found the knee conditions less likely than not related to or aggravated by the foot condition, citing lack of severe gait alteration. Despite these negative findings for direct service connection, the Board found the veteran's testimony regarding altered gait due to foot pain causing knee flare-ups to be competent and credible, leading to a finding of secondary aggravation. Service connection for bilateral knee disabilities as secondary to pes planus with plantar fasciitis was granted.

Rationale

No in-service knee complaints documented in STRs or separation exam.; Veteran's testimony regarding in-service knee issues contradicted by service records.; VA exams found knee conditions less likely than not related to or aggravated by foot condition.; Board found veteran's testimony regarding altered gait due to foot pain causing knee flare-ups to be competent and credible, establishing aggravation.

Full Decision Text

Citation Nr: 26000556
Decision Date: 01/15/26	Archive Date: 01/15/26

DOCKET NO. 19-23 792
DATE: January 15, 2026

ORDER

Service connection for a right knee disability, as secondary to service-connected bilateral pes planus with plantar fasciitis, is granted.

Service connection for a left knee disability, as secondary to service-connected bilateral pes planus with plantar fasciitis, is granted.

FINDINGS OF FACT

1. The right knee disability is aggravated by the service-connected bilateral pes planus with plantar fasciitis. 

2. The left knee disability is aggravated by the service-connected bilateral pes planus with plantar fasciitis. 

CONCLUSIONS OF LAW

1. The criteria for entitlement to service connection for right knee disability have been met. 38 U.S.C. §§ 1101, 1110, 1112, 1113, 1131, 1137, 5107; 38 C.F.R. §§ 3.102, 3.303, 3.307, 3.309, 3.310.

2. The criteria for entitlement to service connection for left knee disability have been met. 38 U.S.C. §§ 1101, 1110, 1112, 1113, 1131, 1137, 5107; 38 C.F.R. §§ 3.102, 3.303, 3.307, 3.309, 3.310.

REASONS AND BASES FOR FINDINGS AND CONCLUSIONS

The Veteran served on active duty in the United States Army from August 1989 to May 1992 and had subsequent service in the Army Reserve. This matter comes before the Board of Veterans' Appeals (Board) from an August 2018 decision by a Department of Veterans Affairs (VA) agency of original jurisdiction (AOJ).

The Veteran testified before the undersigned in a May 2021 Board hearing; a transcript of the hearing is of record. The Board remanded this matter in February 2022 for further development.

In December 2022, the Board denied the captioned issues. The Veteran appealed the decision to the United States Court of Veterans' Appeals (Court). In a February 2024 memorandum decision, the Court set aside the December 2022 decision and remanded this matter back to the Board. The Board again denied the service connection claims for the bilateral knees in July 2024. The Veteran appealed this decision to the Court; and the Court effectuated a January 2025 Joint Motion for Remand (JMR) vacating the July 2024 decision. In May 2025, the Board remanded the case for development consistent with the January 2025 JMR. 

The Veteran contends that his left and right knee disabilities are secondary to his service-connected pes planus with plantar fasciitis.

Service connection is warranted where the evidence of record establishes that a particular injury or disease resulting in disability was incurred in the line of duty in the active military service or, if pre-existing such service, was aggravated thereby. 38 U.S.C. §§ 1110, 1131; 38 C.F.R. § 3.303. If a condition noted during service is not shown to be chronic, then generally a showing of continuity of symptomatology after service is required for service connection if the disability is one that is listed in 38 C.F.R. § 3.309. 38 C.F.R. § 3.303(b); see also Walker v. Shinseki, 708 F.3d 1331 (Fed. Cir. 2013).

In addition, service connection also may be granted on the basis of a post-service initial diagnosis of a disease, where the physician relates the current condition to the period of service. 38 C.F.R. § 3.303(d). Other specifically enumerated disorders, including arthritis, will be presumed to have been incurred in service if they manifested to a compensable degree within the first year following separation from active duty. 38 U.S.C. §§ 1101, 1112, 1113; 38 C.F.R. §§ 3.307, 3.309.

In this regard, in order to establish service connection for the claimed disorders, there must be (1) medical evidence of a current disability, (2) medical, or in certain circumstances, lay evidence of in-service incurrence or aggravation of a disease or injury, and (3) medical evidence of a nexus between the claimed in-service disease or injury and the current disability. See Hickson v. West, 12 Vet. App. 247 (1999).

For secondary service connection,
 a compensable degree within the first year following separation from active duty. 38 U.S.C. §§ 1101, 1112, 1113; 38 C.F.R. §§ 3.307, 3.309.

In this regard, in order to establish service connection for the claimed disorders, there must be (1) medical evidence of a current disability, (2) medical, or in certain circumstances, lay evidence of in-service incurrence or aggravation of a disease or injury, and (3) medical evidence of a nexus between the claimed in-service disease or injury and the current disability. See Hickson v. West, 12 Vet. App. 247 (1999).

For secondary service connection, it must be shown that the disability for which the claim is made is proximately due to or aggravated by a service-connected disability. See 38 C.F.R. § 3.310; Allen v. Brown, 7 Vet. App. 439 (1995) (en banc).

In evaluating the evidence, the Board has the duty to assess its credibility and weight. Davidson v. Shinseki, 581 F. 3d 1313 (Fed. Cir. 2009); Jandreau v. Nicholson, 492 F. 3d 1372 (Fed. Cir. 2007). Indeed, the Court has declared that, in adjudicating a claim, the Board has the responsibility to do so. Bryan v. West, 13 Vet. App. 482, 488-89 (2000).

Except as otherwise provided by law, a claimant has the responsibility to present and support a claim for benefits under the laws administered by VA. VA shall consider all information and medical and lay evidence of record. Where there is an approximate balance of positive and negative evidence regarding any issue material to the determination of a matter, VA shall give the benefit of the doubt to the claimant. 38 U.S.C. § 5107; 38 C.F.R. § 3.102; see also Gilbert v. Derwinski, 1 Vet. App. 49 (1990).

The Veteran's service treatment records (STRs) do not document any knee diagnosis, treatment, complaint, or symptoms. The Veteran's separation examination in March 1992 found no issue with the Veteran's knees and the Veteran did not report any knee issues. The Veteran was placed on profile for no running due to chronic bilateral plantar fasciitis, bilateral tibial tendonitis, and bilateral Achillis' tendonitis in November 2011 and December 2012.  

VA treatment records indicate that in August 2017, the Veteran reported knee pain occurring for the past 6 months. In October 2017, the Veteran reported a history of left knee pain since the 1990s. The Veteran reported there was no injury. In November 2017, the Veteran was diagnosed with arthritis of the left knee; the Veteran reported that he had bilateral knee pain for the past 10 to 15 years and had no history of trauma.

In August 2018, the Veteran underwent a VA knee examination. The examiner diagnosed the Veteran with bilateral knee degenerative arthritis. During the examination, the Veteran reported that he had chronic bilateral knee issues since active duty, which had only gotten worse over the intervening decades. The examiner noted that the Veteran's diagnosis of bilateral knee arthritis was sometime in the 2000s. The examiner found the Veteran's bilateral knee degenerative joint disease is less likely than not secondary to his service-connected bilateral pes planus and plantar fasciitis. The examiner reasoned that the current peer-reviewed medical literature does not support a causal relationship between foot pathology and the subsequent development of the knee pathology issues. The examiner further noted that the Veteran's STRs do not contain any documentation of knee issues or injuries.

In September 2019, the Veteran underwent another VA knee examination. The examiner diagnosed the Veteran with bilateral patellofemoral pain syndrome. During the examination, the Veteran reported that he had bilateral knee pain while on active duty. The Veteran stated that he did not recall an injury or trauma. He stated he believed he was seen on active duty but did not recall any treatment or diagnosis. The Veteran stated he noticed achy pain with running. The Veteran reported that he believed he received an injection while stationed in Germany. The examiner opined that the current bilateral knee condition is less likely than not aggravated by the bilateral foot condition. The examiner opined that there was no evidence of any aggravation due to the Veteran's bilateral feet. The examiner stated that there is nothing found in the currently accepted, peer-reviewed, credible, and authoritative orthopedic literature that demonstrates that a bilateral feet condition (including pes planus with or without plantar fasciitis and/or altered gait pattern) will induce aggravation to
 recall an injury or trauma. He stated he believed he was seen on active duty but did not recall any treatment or diagnosis. The Veteran stated he noticed achy pain with running. The Veteran reported that he believed he received an injection while stationed in Germany. The examiner opined that the current bilateral knee condition is less likely than not aggravated by the bilateral foot condition. The examiner opined that there was no evidence of any aggravation due to the Veteran's bilateral feet. The examiner stated that there is nothing found in the currently accepted, peer-reviewed, credible, and authoritative orthopedic literature that demonstrates that a bilateral feet condition (including pes planus with or without plantar fasciitis and/or altered gait pattern) will induce aggravation to the knees.

In June 2020, the Veteran submitted a private opinion from his physical therapist. The physical therapist stated that that the Veteran was seen for physical therapy for bilateral knee osteoarthritis and chronic knee pain. The physical therapist stated that it was his professional opinion that other concurrent issues such as bilateral feet and Achilles' tendon tightness have contributed to the Veteran's current knee problem. No rationale was offered.

In May 2021, the Veteran testified in a Board hearing. The Veteran stated that the pain in his knees began while he was in service. The Veteran stated that he was not allowed to reenlist in the reserves because he failed his physical training test, due to his knees and feet. The Veteran testified that he believed his knee issue was related to his feet. The Veteran stated that when he compensates for his feet, such as by walking on the outside of his feet, limping, or leaning on a wall when walking, his knees begin to hurt.

In March 2022, the Veteran underwent another VA examination. The examiner diagnosed the Veteran with patellofemoral pain syndrome and ostearthritis in both knees. During the examination the Veteran stated that during physical training he hurt his right and left knees. The Veteran noted he went to sick call and was given a profile for no physical training for several days. The Veteran stated he was seen for his knees in Germany. The March 2022 examiner opined that the Veteran's bilateral knee disabilities were less likely than not incurred in or caused by the claimed in-service injury, event, or illness. The examiner reasoned that although the Veteran had osteoarthritis in the right knee and degenerative arthritis in the left knee, it was not manifested within one year from separating from active duty and there were "no notes during service with continuity of the same symptoms since service."

Clarification was sought in July 2022, when the examiner repeated the negative nexus opinions regarding causation and aggravation. The examiner commented that although the Veteran reported in-service knee problems, such was not consistent with the documentary evidence in STRs or contemporary statements by the Veteran in service. He specified that the first documentation of knee problems was in 2017, 25 years after active duty. The examiner noted that the Veteran lacked the medical knowledge to render a nexus opinion, and found that as the only evidence of a link between current problems and service was the Veteran's reports, no nexus was established.

In June 2025, the Veteran underwent another VA knee examination. The examiner diagnosed the Veteran with bilateral knee joint osteoarthritis. During the examination, the Veteran reported that his knee pain began while on active duty. He stated that his symptoms remained persistent. He reported pain could fluctuate with physical activity and exertion. The examiner opined that the right and left knee disabilities were less likely than not proximately due to or the result of the Veteran's service-connected bilateral pes planus with bilateral plantar fasciitis. The examiner explained that there is no clear evidence from a review of the orthopedic literature to suggest that an injury to one joint would have any significant impact on another or opposite uninjured joint or limb, unless the injury resulted in a major muscle or nerve damage causing partial or complete paralysis, or shortening of the injured limb resulting in length discrepancy of more than 5 centimeters so that the individuals gait pattern has been altered to the extent that clinically there is an obvious Trendelenburg gait. The examiner noted that this level of severity is not supported based on the record review, history or examination. The examiner concluded that the knees are separate entities entirely from the pes planus with plantar fascitis and are unrelated to it. The examiner also opined that the knee disabilities were less likely than not aggravated by the pes planus with plantar fasciitis. She reiterated that the evidence did not support obvious Trendelenburg gait, which would damage the joints in question. The examiner further explained that the current medical history, physical examination, and service treatment record did not support an unusual progression or aggravation regarding the bilateral knee disability. The examiner concluded that there is no medical evidence to support aggravation without resorting to
burg gait. The examiner noted that this level of severity is not supported based on the record review, history or examination. The examiner concluded that the knees are separate entities entirely from the pes planus with plantar fascitis and are unrelated to it. The examiner also opined that the knee disabilities were less likely than not aggravated by the pes planus with plantar fasciitis. She reiterated that the evidence did not support obvious Trendelenburg gait, which would damage the joints in question. The examiner further explained that the current medical history, physical examination, and service treatment record did not support an unusual progression or aggravation regarding the bilateral knee disability. The examiner concluded that there is no medical evidence to support aggravation without resorting to mere speculation. 

In August 2025, the June 2025 examiner provided an addendum medical opinion. She again opined that the bilateral knee joint osteoarthritis and pes planus with bilateral plantar fasciitis are not medically related. She stated that knee osteoarthritis is a separate entity entirely from pes planus with plantar fasciitis and they are unrelated. The examiner stated it is not plausible to conclude the Veteran's knee conditions were aggravated or had an increase in severity that is proximately due to or the result of the pes planus with bilateral plantar fasciitis without mere speculation. 

Initially, the Board finds that while the Veteran is competent to report having experienced symptoms of right and left knee pain at any time, as a lay person, under the facts of this case, the Veteran does not have the requisite medical training or credentials to be able to render a competent medical opinion concerning whether a currently diagnosis of bilateral knee arthritis and/or patellofemoral pain syndrome is related to alleged in-service knee treatment or was caused or aggravated by any foot disability. These issues are medically complex, as it requires knowledge of the orthopedic system and interpretation of complicated diagnostic medical testing. See Jandreau v. Nicholson, 492 F.3d 1372, 1376-77 (Fed. Cir. 2007); Clyburn v. West, 12 Vet. App. 296, 301 (1999); Savage v. Gober, 10 Vet. App. 488, 496-97 (1997).

Further, the Board finds that the Veteran's statements that his knee pain began in-service, and he was placed on profile due to his knee disabilities, are not credible even if he were competent. The Veteran's STRs indicate that the Veteran was placed on profile due to his bilateral plantar fasciitis, bilateral tibial tendonitis, and bilateral Achilles' tendonitis, not any knee pain. Further, the Veteran's March 1992 separation examination and periodic examinations for reserve service do not indicate any knee pain and the Veteran did not report any knee pain by history. Such findings are inconsistent with the Veteran's statements that his knee pain began in-service and that he received care for his knees in-service. It is not simply that his statements are not corroborated; they are directly contradicted, as he was not placed on profile due to his knees. Thus, the Veteran's statements that his knee pain began in-service have no probative value.

In an argument before the Court, the Veteran's representative notes that this inconsistency regarding being placed on profile is immaterial and therefore should not go to the credibility of the Veteran's statement. The Board disagrees. The Veteran's statement regarding being treated for his knees and being placed on profile is evidence regarding the event triggering his disabilities. Evidence regarding the onset of the knee disabilities is material considering that the Veteran has claimed he has had pain since the onset of the disabilities. Such that if the Board finds the statement regarding the onset of his knee disabilities is not credible, it follows that his statements regarding knee symptoms since that time are also not credible. 

The Board finds that the August 2018 and September 2019 VA medical opinions were found to be inadequate, as they relate to secondary service connection. The opinions relied on an absence of medical literature and did not discuss the Veteran's medical history. 

Further, the March 2022 and July 2022 examination and opinions are adequate as they relate to direct service connection. The opinions are well reasoned, detailed, and include consideration of the Veteran's relevant medical history. See Prejean v. West, 13 Vet. App. 444, 448-9 (2000); Nieves-Rodriguez v. Peake, 22 Vet. App. 295, 304 (2008). The Board finds the opinions are probative as they are adequate and related to direct service connection and presumptive service connection. The Board finds persuasive the examiner's explanation that there is no evidence of an in-service injury other than the reports of pain in-service. As noted above, the Veteran's statements that his knee
 and July 2022 examination and opinions are adequate as they relate to direct service connection. The opinions are well reasoned, detailed, and include consideration of the Veteran's relevant medical history. See Prejean v. West, 13 Vet. App. 444, 448-9 (2000); Nieves-Rodriguez v. Peake, 22 Vet. App. 295, 304 (2008). The Board finds the opinions are probative as they are adequate and related to direct service connection and presumptive service connection. The Board finds persuasive the examiner's explanation that there is no evidence of an in-service injury other than the reports of pain in-service. As noted above, the Veteran's statements that his knee pain began in service are not probative because they lack credibility. Indeed, in the July 2022 clarification, the examiner notes that the only evidence is the Veteran's own reports of knee pain, which the examiner found inconsistent with the examined medical records. The March 2022 VA examiner found the Veteran's knee disabilities were less likely than not related to service because there was no in-service event. The Board finds this reasoning adequate and persuasive.

The Board finds that the June 2025 and August 2025 medical opinions as they relate to the causation prong of secondary service connection is adequate. The opinions are well reasoned, detailed, and include consideration of the Veteran's relevant medical history. See Prejean v. West, 13 Vet. App. 444, 448-9 (2000); Nieves-Rodriguez v. Peake, 22 Vet. App. 295, 304 (2008). The Board finds persuasive the examiner's explanation that the severity of the Veteran's pes planus and plantar fasciitis was not so severe to cause the Veteran's bilateral knee disabilities. However, the Board finds that the examiner's aggravation opinion is not adequate. In June 2025, the examiner noted that the evidence did not indicate an unusual progression or aggravation of the knee disabilities and she could not support aggravation without resorting to mere speculation. In August 2025, the examiner explained that it was not plausible to conclude the knee disabilities were aggravated by the foot disabilities without mere speculation. However, the examiner did not discuss the Veteran's physical therapist statement that his feet contributed to the knee disability, or the Veteran's Board testimony regarding compensation for his foot pain causes flare-ups in his knees.   

Based upon the evidence, the Board finds there was no in-service event or injury that caused the currently diagnosed knee disabilities. Thus, service connection for the Veteran's knee disabilities on a direct basis is not warranted.

In addition, there is no evidence that the Veteran's arthritis began within one year of his service or was noted in-service. Specifically, the Veteran was first diagnosed with arthritis in the left knee in 2017.  At the time of his diagnosis, the Veteran stated his bilateral knee pain began 10 to 15 years prior, well after his active duty service. Therefore, presumptive service connection is not warranted.

Despite the above, however, the Board, providing all benefit of the doubt to the Veteran, finds that his bilateral knee disabilities were aggravated by his plantar fasciitis and pes planus. In this, the Board finds no adequate medical examination regarding whether the Veteran's pes planus with plantar fascitis aggravated the bilateral knee disabilities. Despite the lack of any adequate medical opinions, the Board finds that the Veteran's uncontradicted testimony that he walks differently at times due to his feet pain, which caused flare-ups in his knees is competent and credible. Flare-ups in the knees triggered by limping or walking differently due to foot pain from pes planus and plantar fasciitis is aggravation. Service connection based on secondary aggravation does not require that the aggravation is permanent. See Ward v. Wilkie, 31 Vet. App. 233, 241-42 (2019). Therefore, service connection based on aggravation is warranted. 

 

 

WILLIAM H. DONNELLY

Veterans Law Judge

Board of Veterans' Appeals

Attorney for the Board	Robert Batten

The Board's decision in this case is binding only with respect to the instant matter decided. This decision is not precedential and does not establish VA policies or interpretations of general applicability. 38 C.F.R. § 20.1303.