DIABETES MELLITUS
THOMAS H. O'SHAY · 2026 · Case ID: 26000995
Summary
The veteran served from November 1972 to September 1975, and again from April 1977 to September 1986. The veteran appeals the denial of service connection for diabetes mellitus, contending it was caused or worsened by his service-connected adjustment disorder with depression. The Board reviewed the evidence, noting that service treatment records were silent regarding diabetes or blood sugar concerns. A July 2003 VA treatment record indicated a diagnosis of diabetes approximately 1.5 years prior, suggesting an onset well after service. The Board found no evidence of continuity of symptomatology from service. A June 2025 VA examination concluded that the veteran's diabetes was less likely than not proximately due to or the result of his service-connected adjustment disorder with depression. The examiner cited the veteran's longstanding history of morbid obesity as the primary factor for diabetes development and stated that while psychological stress can influence lifestyle, a direct pathophysiological link between adjustment disorder and diabetes is unsupported by current medical evidence. The examiner opined that the adjustment disorder did not cause or aggravate the diabetes, as the progression correlated with metabolic risk factors like obesity. The Board found the VA opinion probative and persuasive, supported by clear rationale. The Board concluded that the veteran's diabetes was not present in service or within one year of discharge, and no competent evidence linked it to service or service-connected disability. Therefore, service connection for diabetes is denied.
Rationale
No evidence of diabetes in service treatment records.; Diagnosis of diabetes approximately 1.5 years after service.; VA examiner opined diabetes less likely than not due to service-connected adjustment disorder.; Examiner cited obesity and metabolic factors as primary cause of diabetes.; No direct pathophysiological link between adjustment disorder and diabetes.; Adjustment disorder did not aggravate diabetes.
Full Decision Text
Citation Nr: 26000995 Decision Date: 01/28/26 Archive Date: 01/28/26 DOCKET NO. 19-03 438A DATE: January 28, 2026 ORDER Entitlement to service connection, to include on a secondary basis, for diabetes is denied. FINDING OF FACT The Veteran's diabetes did not originate in service or manifest to a compensable degree within one year of service discharge, and is not otherwise etiologically related to service; nor was the diabetes caused or worsened by service-connected disability. CONCLUSION OF LAW The criteria for service connection for diabetes are not met. 38 U.S.C. §§ 1110, 1131, 5107; 38 C.F.R. §§ 3.102, 3.303, 3.307, 3.309, 3.310. REASONS AND BASES FOR FINDING AND CONCLUSION The Veteran had active service from November 1972 to September 1975, and from April 1977 to September 1986. This matter comes before the Board of Veterans' Appeals (Board) on appeal from a rating action by a Department of Veterans Affairs (VA) Regional Office (RO). By way of history, in April 2023, the Board issued a decision that denied entitlement to a rating in excess of 50 percent for adjustment disorder with depression. The Veteran appealed the denial to the U.S. Court of Appeals for Veterans Claims, and in an August 2024 Order, that court granted a Joint Motion for Remand (JMR) filed by the parties. This matter was last before the Board in May 2025, when it was remanded for further development. 1. Entitlement to service connection for diabetes is denied. The Veteran contends that his diabetes was in some way either caused or worsened by his service-connected psychiatric disorder. Service connection may be granted for a disability resulting from disease or injury incurred in or aggravated by active service. 38 U.S.C. §§ 1110, 1131; 38 C.F.R. § 3.303(a). To establish a right to compensation for a present disability, a Veteran 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. Holton v. Shinseki, 557 F.3d 1362, 1366 (Fed. Cir. 2009) (quoting Shedden v. Principi, 381 F.3d 1163, 1167 (Fed. Cir. 2004)). Certain chronic diseases are subject to presumptive service connection if manifest to a compensable degree within one year from separation from service even though there is no evidence of such disease during the period of service. 38 U.S.C. §§ 1112, 1113; 38 C.F.R. §§ 3.307 (a)(3), 3.309(a). Continuity of symptomatology may also provide a basis for a grant of service connection for those diseases defined as "chronic" by VA. 38 C.F.R. § 3.303(b); Walker v. Shinseki, 708 F.3d 1331 (Fed. Cir. 2013). Service connection may also be established on a secondary basis for a disability that is proximately due to or the result of or aggravated by a service-connected disease or injury. 38 C.F.R. § 3.310(a); Allen v. Brown, 7 Vet. App. 439, 446 (1995) (en banc). In order to establish service connection for a claimed secondary disorder, there must be medical evidence of a current disability; evidence of a service-connected disability; and medical evidence of a nexus between the service-connected disability and the current disability. See Wallin v. West, 11 Vet. App. 509, 512 (1998); Reiber v. Brown, 7 Vet. App. 513, 516-7 (1995); see also Spicer v. McDonough, 61F.4th 1360 (Fed. Cir. 2023) (secondary aggravation will be shown where a non-service-connected disability would have been less severe "but-for" a service-connected disability, either because there is an etiological link (to include worsening of functionality) between the two conditions, or because the service-connected disability resulted in the inability to treat the non-service-connected disability). The Veteran contends that because an April 2016 VA treatment record identifies the Veteran's report that he 11 Vet. App. 509, 512 (1998); Reiber v. Brown, 7 Vet. App. 513, 516-7 (1995); see also Spicer v. McDonough, 61F.4th 1360 (Fed. Cir. 2023) (secondary aggravation will be shown where a non-service-connected disability would have been less severe "but-for" a service-connected disability, either because there is an etiological link (to include worsening of functionality) between the two conditions, or because the service-connected disability resulted in the inability to treat the non-service-connected disability). The Veteran contends that because an April 2016 VA treatment record identifies the Veteran's report that he had been overeating and having a "difficult time controlling his sugar consumption" because of his stress, the claim of entitlement to service connection for diabetes as secondary to his service-connected adjustment disorder with depression was reasonably raised by the record. He does not otherwise contend that his diabetes began in service, or is directly related to his military service, nor is this shown by the record to be the case. Service treatment records are silent for any reference to diabetes or for any concerns raised about the Veteran's blood sugar readings. This evidence weighs against a finding that diabetes had its onset during the Veteran's military service. There is also insufficient evidence of continuity of symptoms in the immediate years after. A July 2003 VA treatment record documents the Veteran's report that he was diagnosed with diabetes 1.5 years prior (so, approximately 2001, or more than a decade after service), with his progressive obesity. Because there is no objective evidence that the Veteran was diagnosed with diabetes in service or within one year of service discharge, service connection may not be made on a presumptive basis under 38 C.F.R. §§ 3.307 or 3.309(a). No medical evidence has been submitted suggesting a link between the Veteran's diabetes and his period of service. The Veteran was examined by VA in June 2025. The examiner determined that the Veteran's diabetes was less likely than not (less than 50 percent probability) proximately due to or the result of the Veteran's service-connected adjustment disorder with depression. The examiner explained that the Veteran's medical record demonstrated a longstanding history of severe obesity with a body mass index (BMI) persistently over 40, which was a well-established primary factor for the development of type 2 diabetes mellitus; the examiner explained the mechanism by which obesity leads to diabetes. The examiner explained that although the Veteran reported stress and difficulty controlling sugar consumption during an April 2016 VA visit, psychological stress and adjustment disorder have not been shown to directly cause diabetes in the absence of other metabolic risk factors. The examiner further explained that psychological conditions may influence lifestyle factors, but the direct pathophysiological link between adjustment disorder and diabetes is unsupported by current medical evidence. The examiner opined that the Veteran's persistent morbid obesity and associated metabolic derangements provide a sufficient and well-documented explanation for his diabetes. Therefore, based on established medical literature and clinical evidence, the Veteran's service-connected adjustment disorder did not cause his diabetes mellitus. The examiner further opined that adjustment disorder did not aggravate the Veteran's diabetes. In this regard, the examiner explained that the Veteran's diabetes progression correlated with his well-documented metabolic risk factors, including obesity and likely other comorbidities such as hypertension and hyperlipidemia, rather than his adjustment disorder. In other words, the examiner concluded that there simply was no relationship in this case, direct or aggravation-based, between the psychiatric disorder and the claimed diabetes. Based on the foregoing, the Board finds that the Veteran's diabetes is not related to service, nor is it due to or aggravated by his service-connected adjustment disorder with depression. The VA opinion is both probative and persuasive medical evidence in this case, as it is based upon a review of the claims file and supported by sufficiently clear and well-reasoned medical rationale. In providing the rationale, the examiner considered the Veteran's specific medical history, the onset and course of the pertinent symptoms, and the results of the clinical evaluations. See Nieves-Rodriguez v. Peake, 22 Vet. App. 295, 304 (2008) (the probative value of a medical opinion is derived from a factually accurate, fully articulated, and soundly reasoned opinion). The claims file contains no favorable competent medical evidence refuting them. To the extent the Veteran attempts to provide a lay nexus opinion between his diabetes and his service-connected adjustment disorder with depression, such an assertion treads into the realm of medical expertise. Jandreau v. Nicholson, 492 F.3d 1372, 1377 n.4 (Fed. Cir. 200 and course of the pertinent symptoms, and the results of the clinical evaluations. See Nieves-Rodriguez v. Peake, 22 Vet. App. 295, 304 (2008) (the probative value of a medical opinion is derived from a factually accurate, fully articulated, and soundly reasoned opinion). The claims file contains no favorable competent medical evidence refuting them. To the extent the Veteran attempts to provide a lay nexus opinion between his diabetes and his service-connected adjustment disorder with depression, such an assertion treads into the realm of medical expertise. Jandreau v. Nicholson, 492 F.3d 1372, 1377 n.4 (Fed. Cir. 2007). The relationship between a psychiatric condition and a physical one is clearly something that requires medical education, training or expertise. In any event, the probative value of the Veteran's belief would be outweighed by that of the examiner, who clearly has the education, training, and experience to address the etiology of diabetes mellitus and endocrine disorders. Because the Veteran's diabetes was not present in service or within a year of service, and there is no competent evidence relating it to service or service-connected disability, the claim cannot be granted. 38 C.F.R. §§ 3.303, 3.307, 3.309, 3.310; Allen, supra; see also, Wallin, Reiber, Spicer supra. Accordingly, the evidence is persuasively against the claim and there is no reasonable doubt to be resolved. 38 U.S.C. § 5107(b); 38 C.F.R. § 3.102; Lynch v. McDonough, 21 F.4th 776 (Fed. Cir. 2021). Thomas H. O'Shay Veterans Law Judge Board of Veterans' Appeals Attorney for the Board Asare, Ama K. 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.