Back to BVA DecisionsGRANTEDService Branch ARMY Special Benefit NO SPECIAL BENEFIT Docket No. 14-23 844
HYPERTENSION
THOMAS L. ENGLISH · 2026 · Case ID: 26004219
Summary
The Veteran served in the United States Army from February 1980 to August 1981. This case comes before the Board of Veterans' Appeals (Board) following a September 2010 rating decision and a December 2023 remand. The Veteran sought service connection for hypertension, gastroesophageal reflux disease (GERD), and coronary artery disease, claiming they are secondary to his service-connected unspecified depressive disorder, with obesity as an intermediate step. The Board found current diagnoses for all three conditions, supported by post-service VA treatment records and examinations. VA medical opinions obtained after the remand were negative, stating it was less likely that the Veteran's conditions were caused or aggravated by his depressive disorder, though one examiner noted obesity as a contributing factor and a side effect of antidepressants. However, post-service records showed the Veteran gained approximately 75 pounds while taking antidepressants for his service-connected depression. The Board found an approximate balance of evidence regarding whether the depression caused weight gain leading to hypertension, GERD, and coronary artery disease. Resolving all reasonable doubt in the Veteran's favor, the Board granted service connection for hypertension, GERD, and coronary artery disease secondary to his unspecified depressive disorder, with obesity acting as an intermediate step.
Rationale
Hypertension diagnosed post-service; Secondary to service-connected unspecified depressive disorder; Obesity as intermediate step; Benefit of doubt applied
Full Decision Text
Citation Nr: 26004219 Decision Date: 04/06/26 Archive Date: 04/06/26 DOCKET NO. 14-23 844 DATE: April 6, 2026 ORDER Service connection for hypertension, secondary to service-connected unspecified depressive disorder, is granted. Service connection for gastroesophageal reflux disease (GERD), secondary to service-connected unspecified depressive disorder, is granted. Service connection for coronary artery disease, secondary to service-connected unspecified depressive disorder, is granted. FINDINGS OF FACT 1. Resolving reasonable doubt in favor of the Veteran, her hypertension is proximately due to her service-connected unspecified depressive disorder, with obesity as an intermediate step. 2. Resolving reasonable doubt in favor of the Veteran, her GERD is proximately due to her service-connected unspecified depressive disorder, with obesity as an intermediate step. 3. Resolving reasonable doubt in favor of the Veteran, her coronary artery disease is proximately due to her service-connected unspecified depressive disorder, with obesity as an intermediate step. CONCLUSIONS OF LAW 1. The criteria for service connection for hypertension are met. 38 U.S.C. §§ 1131, 5107; 38 C.F.R. §§ 3.102, 3.303, 3.310. 2. The criteria for service connection for GERD are met. 38 U.S.C. §§ 1131, 5107; 38 C.F.R. §§ 3.102, 3.303, 3.310. 3. The criteria for service connection for coronary artery disease are met. 38 U.S.C. §§ 1131, 5107; 38 C.F.R. §§ 3.102, 3.303, 3.310. REASONS AND BASES FOR FINDINGS AND CONCLUSIONS The Veteran served on active duty in the United States Army from February 1980 to August 1981. These matters come before the Board of Veterans' Appeals (Board) on appeal from a September 2010 rating decision by the Department of Veterans Affairs (VA) Regional Office (RO) and were most recently remanded by the Board in December 2023. In a September 2024 rating decision, the RO granted service connection for headaches. This represents a full grant of the benefits sought, and the issue is no longer in appellate status. See Grantham v. Brown, 114 F. 3d 1156, 1158 (Fed. Cir. 1997). The Board's December 2023 remand directed the RO to determine if the Veteran participated in toxic exposure risk activity (TERA) and to obtain adequate medical opinions as to secondary service connection, to include consideration of obesity as an intermediate step. The Board finds that there has been substantial compliance with its December 2023 remand directives, and it will proceed with adjudication of the issues on appeal. Stegall v. West, 11?Vet. App.?268 (1998). Service Connection Service connection may be granted for a disability resulting from disease or injury incurred in or aggravated by active military service. 38 U.S.C. § 1110; 38 C.F.R. § 3.303. Generally, the evidence must show: (1) the existence of a present disability; (2) in-service incurrence or aggravation of a disease or injury; and (3) a causal relationship between the present disability and the disease or injury incurred or aggravated during service. Shedden v. Principi, 381 F.3d 1163, 1167 (Fed. Cir. 2004). Service connection may be granted for any disease diagnosed after discharge, when all the evidence, including that pertinent to service, establishes that the disease was incurred in service. 38 C.F.R. § 3.303(d). Service connection may also be granted on a secondary basis for a disability that is due to or aggravated by a service-connected disease or injury. Establishing service connection on a secondary basis requires that there is sufficient evidence to show that (1) a current disability exists and (2) the current disability was either (a) caused by or (b) aggravated by a service-connected disability. Allen v. Brown, 7 Vet. App. 439, 448 (1995) (en banc); see also Spicer v. McDonough, 61 F.4th 1360, 1364 (Fed. Cir. 2023) (invalidating the requirement of "proximate cause" and instead holding "but for" causation or aggravation is enough to show entitlement to secondary service connection). A permanent worsening is not required, as secondary service connection is warranted ing service connection on a secondary basis requires that there is sufficient evidence to show that (1) a current disability exists and (2) the current disability was either (a) caused by or (b) aggravated by a service-connected disability. Allen v. Brown, 7 Vet. App. 439, 448 (1995) (en banc); see also Spicer v. McDonough, 61 F.4th 1360, 1364 (Fed. Cir. 2023) (invalidating the requirement of "proximate cause" and instead holding "but for" causation or aggravation is enough to show entitlement to secondary service connection). A permanent worsening is not required, as secondary service connection is warranted for any incremental increase in disability or any additional impairment of earning capacity in non-service-connected disabilities resulting from service-connected conditions regardless of its permanence. Ward v. Wilkie, 31 Vet. App. 233, 239 (2019). In determining whether service connection is warranted for a disability, VA is responsible for determining whether the evidence persuasively favors the claim or is in approximate balance, with the Veteran prevailing in either event, or whether the evidence persuasively weighs against the claim, in which case the claim is denied. In other words, when there is an approximate balance of positive and negative evidence regarding any issue material to the determination, the benefit of the doubt is afforded to the claimant. 38 U.S.C. § 5107; 38 C.F.R. § 3.102; Lynch v. McDonough, 21 F.4th 776 (2021). 1. Entitlement to service connection, to include on a secondary basis, for hypertension 2. Entitlement to service connection, to include on a secondary basis, for GERD 3. Entitlement to service connection, to include on a secondary basis, for coronary artery disease The Veteran seeks service connection for hypertension, GERD, and coronary artery disease, which she contends are caused by her service-connected unspecified depressive disorder. There is no dispute that the Veteran has current diagnoses of hypertension, GERD, and coronary artery disease, as evidence by post-service VA treatment records and VA examinations. As the record shows the presence of current disabilities, the remaining question is whether the Veteran's hypertension, GERD, and coronary artery disease are medically linked to an incident of service, had onset therein, or ar related to a service-connected disability. Pursuant to the Board's December 2023 remand, VA medical opinions as to secondary service connection were obtained in May 2024. The VA examiner provided negative nexus opinions, finding that it is less likely that the Veteran's hypertension, GERD, and coronary artery disease were caused or aggravated by her service-connected unspecified depressive disorder. Regarding the Veteran's hypertension, the examiner indicated that hypertension is caused by many factors, including obesity. As to the Veteran's coronary artery disease, the examiner also indicated that obesity plays a role in the development of coronary artery disease. In an October 2024 VA medical opinion, the examiner opined that obesity is caused by taking in more calories than one burns through exercise, storing excess calories as fat. However, when asked to opine as to whether the Veteran's obesity results from taking medication for any of service-connected disabilities, to include unspecified depressive disorder, the examiner stated that weight gain is a known side effect of nearly all antidepressants. In November 2024 VA medical opinions, the examiner specifically indicated that obesity is a risk factor for the development of hypertension, GERD, and coronary artery disease. Post-service VA treatment records reflect the Veteran has taken antidepressants for her service-connected unspecified depressive disorder for the entire period on appeal. Further, these records show a weight gain of approximately 75 pounds throughout the period on appeal. Obesity can constitute an "intermediate step" in showing secondary service connection, i.e., that service connection is warranted when a service-connected disability causes or aggravates obesity, which in turn causes the claimed disability. Walsh v. Wilkie, 32 Vet. App. 300, 305-07 (2020). Upon review of the relevant evidence, the Board finds there is an approximate balance of positive and negative evidence regarding whether the Veteran's unspecified depressive disorder caused her to gain weight, which in turn led to the development of her hypertension, GERD, and coronary artery disease. Post-service VA treatment records show that, at the time of the Veteran's claim, she was taking prescribed antidepressants for her service-connected unspecified depressive disorder, which she continues to take today. Moreover, these records reflect that the Veteran gained approximately 75 pounds from the time she began taking antidepressants for her service-connected unspecified depressive disorder to the present day. The October 2024 VA examiner confirmed that a side effect of taking antidepressants -07 (2020). Upon review of the relevant evidence, the Board finds there is an approximate balance of positive and negative evidence regarding whether the Veteran's unspecified depressive disorder caused her to gain weight, which in turn led to the development of her hypertension, GERD, and coronary artery disease. Post-service VA treatment records show that, at the time of the Veteran's claim, she was taking prescribed antidepressants for her service-connected unspecified depressive disorder, which she continues to take today. Moreover, these records reflect that the Veteran gained approximately 75 pounds from the time she began taking antidepressants for her service-connected unspecified depressive disorder to the present day. The October 2024 VA examiner confirmed that a side effect of taking antidepressants is weight gain, and the November 2024 VA examiner opined that the Veteran's obesity contributes to the development of her hypertension, GERD, and coronary artery disease. Here, the Board finds there is sufficient evidence to grant service connection for hypertension, GERD, and coronary artery disease, secondary to service-connected unspecified depressive disorder, with obesity playing an intermediate step in the development of these disabilities. (Continued on the next page) In conclusion, resolving all reasonable doubt in favor of the Veteran, service connection for hypertension, GERD, and coronary artery disease is granted. Thomas L. English Veterans Law Judge Board of Veterans' Appeals Attorney for the Board Houle, Denise 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.