PERIPHERAL NEUROPATHY

M. M. CELLI · 2026 · Case ID: A26015368

DENIED

Summary

The Veteran, a Veteran who served from August 1975 to August 1978 and October 1978 to July 1988, appeals the denial of service connection for a neurological disability, separate and distinct from his service-connected migraine headaches. The Veteran claimed this neurological disability, including neuropathy, was due to exposure to contaminated water at Camp Lejeune and cold weather during service. Alternatively, he claimed it was secondary to his service-connected schizophrenia with panic attacks and/or seborrheic dermatitis. The Board reviewed evidence including service treatment records, VA examinations from July and August 2017 with a March 2020 addendum, private medical opinions, and articles submitted by the Veteran. Service treatment records did not reflect complaints or treatment for neuropathy during service. VA examinations found no link between Camp Lejeune contaminants and peripheral neuropathy, noting other potential causes like B12 deficiency and panic attacks, and found the neuropathy less likely than not related to service or secondary to his psychiatric or skin conditions. A private physician's opinion was considered too general and speculative. The Board found the VA examinations adequate and persuasive, concluding the evidence weighed against service connection. The Veteran's own testimony regarding the cause of his neuropathy was not considered competent medical evidence. Service connection for the neurological disability was denied.

Rationale

Service treatment records did not reflect complaints or treatment for neuropathy.; VA examinations found no link between Camp Lejeune contaminants and peripheral neuropathy.; VA examinations noted other potential causes for neuropathy, such as low B12 and elevated A1C.; VA examinations found no link between neuropathy and service-connected psychiatric or skin disabilities.; Private physician opinion was too general and speculative.; Veteran's testimony regarding cause was not competent medical evidence.

Special Benefit

NO SPECIAL BENEFIT

Docket No.

201207-125448

Full Decision Text

Citation Nr: A26015368
Decision Date: 02/19/26 Archive Date: 02/19/26

DOCKET NO. 201207-125448
DATE: February 19, 2026

ORDER

Service connection for a neurological disability, separate and distinct from service-connected migraine headaches, is denied.

FINDING OF FACT

A neurological disability, separate and distinct from service-connected migraine headaches, is not shown to be causally or etiologically related to an in-service event, injury, or disease and is not secondary to a service-connected disability.

CONCLUSION OF LAW

The criteria for service connection for a neurological disability, separate and distinct from service-connected migraine headaches, have not been met. 38 U.S.C. §§ 1131, 5107; 38 C.F.R. §§ 3.102, 3.303, 3.310.

REASONS AND BASES FOR FINDING AND CONCLUSION

The Veteran served on active duty from August 1975 to August 1978 and from October 1978 to July 1988.

This matter comes before the Board of Veterans' Appeals (Board) on appeal from an October 2020 rating decision issued by a Department of Veterans Affairs (VA) Regional Office (RO). This rating decision was a higher-level review decision that considered the evidence of record at the time of a prior May 2020 Supplemental Statement of the Case (SSOC) issued by the RO.

In the December 2020 VA Form 10182, Decision Review Request: Board Appeal (Notice of Disagreement), the Veteran elected to appeal the issue listed above and requested a hearing before the Board and an opportunity to submit evidence. A Board hearing was held on July 18, 2024. Based on the Veteran's docket selection, the Board may only consider the evidence of record at the time of the May 2020 SSOC, which was subject to higher-level review, as well as any evidence submitted at the hearing or within 90 days following the hearing. 38 C.F.R. § 20.302(a). If evidence was submitted either (1) during the period after the Agency of Original Jurisdiction (AOJ) issued the decision on appeal and prior to the Board hearing, or (2) more than 90 days following the hearing, the Board did not consider it in its decision. 38 C.F.R. §§ 20.300, 20.302(a), 20.801.

If the Veteran would like VA to consider any evidence that was submitted that the Board could not consider, the Veteran may file a supplemental claim (VA Form 20-0995) and submit or identify this evidence. 38 C.F.R. § 3.2501. If the evidence is new and relevant, VA will issue another decision on the claim, considering the new evidence in addition to the evidence previously considered. Id. Specific instructions for filing a supplemental claim are included with this decision.

The Veteran contends that he has a neurological disability, to include neuropathy, that is due to his service. Specifically, he claims he has a neurological disability, separate and distinct from his service-connected migraine headaches, that is related to his exposure to contaminated water at Camp Lejeune and also due to his exposure to cold weather while in service. In the alternative, he contends that he has a neurological disability secondary to his service-connected schizophrenia with panic attacks (psychiatric disability) and/or seborrheic dermatitis (skin disability).

Service connection may be granted for disability resulting from disease or injury incurred in or aggravated by active service. 38 U.S.C. §§ 1131, 5107; 38 C.F.R. § 3.303. The three-element test for service connection requires evidence of: (1) a current disability; (2) in-service incurrence or aggravation of a disease or injury; and (3) a causal relationship between the current disability and the in-service disease or injury. Shedden v. Principi, 381 F.3d 1163, 1166 -67 (Fed. Cir. 2004).

Service connection may also be established on a secondary basis for: (1) a disability that is proximately due to or the result of a service-connected disease or injury; or, (2) any increase in the severity of a nonservice-connected disease or injury that is proximately due to or the result of a service-connected disease or injury, and not due to the natural progress of the nonservice-connected disease or injury. 38 C.F.R. §§ 3.310(a)-(b).

For Veterans who are presumed to have been exposed to contaminants in the water supply while serving at Camp Lejeune for no less than 30 days from August 1,
, 1166 -67 (Fed. Cir. 2004).

For Veterans who are presumed to have been exposed to contaminants in the water supply while serving at Camp Lejeune for no less than 30 days from August 1, 1953, to December 31, 1987, VA has established a presumption of service connection for certain diseases. 38 C.F.R. § 3.307(a)(7), 3.309(f). The Veteran has neuropathy, which is not included in the presumptive list. 38 C.F.R. § 3.309(f). However, where a presumption does not exist, VA is to consider whether service connection is warranted on a non-presumptive basis. See Combee v. Brown, 34 F.3d 1039, 1043-1044 (Fed.Cir.1994).

The Veteran's service treatment records do not reflect any complaints of, treatment for, or a diagnosis referable to neuropathy or any other neurological disability other than headaches.

VA treatment records from December 2006 indicate a diagnosis of chronic neuropathy. Private treatment records from March 2021 indicate that the Veteran has sensory peripheral neuropathy in the lower extremities.

In an undated letter received in December 2009, a private physician, F.O., noted that the Veteran's ingested toxic compounds for a long period of time while stationed at Camp Lejeune and opined that such toxic compounds "can be contributory to his symptoms, especially his dermatologic and neurologic disorders".

The Veteran was provided with a VA Camp Lejeune Contaminated Water examination in July 2017. The VA examiner opined that the Veteran's claimed neurological disability was less likely than not due to his past exposure to contaminated water at Camp Lejeune. The examiner noted that "the available evidence does not establish that parkinsonism (parkinsonian syndromes) and other manifestations of small fiber nerve damage are associated with exposure to the contaminants in the water supply at Camp Lejeune." The examiner noted differences between what has been found to be related to exposure to the contaminated water at Camp Lejeune, which include symptoms consistent with central nervous system toxicity, and what the Veteran is claiming, which is "a stocking glove peripheral neuropathy."

The examiner also found relevant that the Veteran had reported symptoms years ago, but four recent annual physical examinations showed that these symptoms were no longer present. The examiner noted that the Veteran's symptoms were noted to be intermittent, radiating into the feet, and did "not resemble symptoms of peripheral neuropathy." These symptoms were noted to be active when the Veteran was "very actively suffering from a panic disorder, likely induced by posttraumatic stress." He added that whatever the symptoms were, "whether resulting from hyperventilation and the panic attacks, or some as yet unexplained phenomenon, or part of a somatoform disorder, they are currently not active and can therefore not be documented." Further, the examiner noted that "the contaminants encountered at Camp Lejeune, trichloroethylene, perchloroethylene, benzene, and vinyl chloride, are simply not associated with the development of peripheral neuropathies."

The Veteran was provided with a VA peripheral nerves conditions examination in August 2017, where he reported feeling "tingling and burning paresthesias in the hands and feet" in 1983 or 1984. The VA examiner noted a diagnosis of peripheral sensory neuropathy, cause undetermined, and opined that this was less likely than not due to the Veteran's service. The rationale provided was that the Veteran was exposed to contaminated water at Camp Lejune from 1975 to 1978, and he reported "the onset of his neuropathy symptoms in approximately 1983, which is 5 years afterward." Additionally, the examiner noted that the Veteran reported a "strong correlation of his sensory paresthesias with his panic attacks." He added that the Veteran had a low-normal B12 level as well as borderline increases in his Hgb A1C, "both of which are known to be associated with peripheral neuropathy". The examiner concluded that the Veteran's "mild neuropathy, which appeared several years after his exposure to contaminated water, is the result of other factors than the water exposure."

The
was that the Veteran was exposed to contaminated water at Camp Lejune from 1975 to 1978, and he reported "the onset of his neuropathy symptoms in approximately 1983, which is 5 years afterward." Additionally, the examiner noted that the Veteran reported a "strong correlation of his sensory paresthesias with his panic attacks." He added that the Veteran had a low-normal B12 level as well as borderline increases in his Hgb A1C, "both of which are known to be associated with peripheral neuropathy". The examiner concluded that the Veteran's "mild neuropathy, which appeared several years after his exposure to contaminated water, is the result of other factors than the water exposure."

The VA examiner also opined that the Veteran's peripheral neuropathy was less likely than not proximately due to his service-connected skin disability. The VA examiner opined that "the Veteran's peripheral sensory neuropathy is of unknown cause, but it is very unlikely that there is any relationship between seborrheic dermatitis and any type of peripheral neuropathy."

In March 2020, a VA examiner opined that the Veteran's neurological disability was less likely than not proximately due to or aggravated by his service-connected skin disability, to include medications taken for such, because "there is no pathology between seborrheic dermatitis and neurological disability." The March 2020 VA examiner also opined that the Veteran's neurological disability was less likely than not proximately due to or aggravated by his service-connected psychiatric disability, because "there is no pathophysiological link for the neurological disability and the psychiatric disability."

The Board finds the July 2017 and August 2017 VA examination reports and accompanying March 2020 addendum opinions are, in combination, adequate for the purpose of determining entitlement to service connection, as they were based on a review of the claims file, an accurate review of the facts in this case, and, when taken together, provide sufficient explanations and rationales to support the opinions. 38 C.F.R. § 3.159(c)(4); Barr v. Nicholson, 21 Vet. App. 303, 307 (2007).

The Board concludes that, while the Veteran has peripheral sensory neuropathy, the evidence of record persuasively weighs against finding that it is secondary to his service-connected psychiatric or skin disabilities or otherwise related to an in-service event, injury, or disease.

The July 2017 and August 2017 VA opinions did not find a link between the Veteran's neuropathy and his exposure to contaminated water at Camp Lejeune. The examiners explained that the chemicals found in the contaminated water at Camp Lejeune have not been shown to cause neuropathy. Further, the August 2017 VA examiner noted that the Veteran had other risk factors, such as low B12 and elevated A1C levels, that were the more likely etiology of his neuropathy. The March 2020 VA opinions did not find a link between the Veteran's neuropathy and his service-connected psychiatric or skin disabilities. The March 2020 VA examiner noted that there was no relationship between the Veteran's neuropathy and his skin disability and no link between his neuropathy and his psychiatric disability. The examiner's combined opinions are probative, because they are based on an accurate medical history and provide an explanation that contain clear conclusions and supporting data. Nieves-Rodriguez v. Peake, 22 Vet. App. 295, 304 (2008).

The Board is cognizant that the July 2017 VA examination report seems to indicate that the Veteran's neuropathy could have resulted from his hyperventilation and panic attacks. However, the Board notes that the July 2017 VA examiner was merely speculating as to the cause of the Veteran's neuropathy. The examiner also indicated that the Veteran's neuropathy could be due to some unexplained phenomenon or part of a somatoform disorder. The examiner did not actually opine that the Veteran's psychiatric disability was the cause of his neuropathy. Even if he did opine that the Veteran's neuropathy was secondary to his psychiatric disability, there was no rationale supporting the opinion. Additionally, the Board notes that in March 2020, a VA examiner concluded that the Veteran's neuropathy was not proximately due to or aggravated by his psychiatric disability and clearly explained that there was no pathophysiological link between the two disabilities.

The Board adds that the August 2017 VA examination report also includes a notation that the Veteran believed there to be a strong correlation between his paresthesias and his panic attacks. However, this was based on the Veteran's own reports and does not reflect the opinion of the VA examiner. As will be explained below, the Veteran is not competent to link
did opine that the Veteran's neuropathy was secondary to his psychiatric disability, there was no rationale supporting the opinion. Additionally, the Board notes that in March 2020, a VA examiner concluded that the Veteran's neuropathy was not proximately due to or aggravated by his psychiatric disability and clearly explained that there was no pathophysiological link between the two disabilities.

The Board acknowledges the undated opinion from F.O. that potentially links a neurological disorder to the Veteran's in-service exposure. However, the specific language utilized by the physician therein is too general and speculative for the purpose of determining entitlement to service connection. 38 C.F.R. § 3.102; Jones v. Shinseki, 23, Vet. App. 382, 389-90 (2010). Additionally, the physician failed to provide any explanation or rationale in support of the favorable opinion. Therefore, the Board does not afford such probative weight.

Similarly, the Board recognizes the Veteran's testimony at the July 2024 Board hearing that the cold weather he was exposed to in service could have aggravated his neuropathy. In support of his claim, the Veteran submitted a November 2020 opinion from a VA physician indicating that "prolonged cold weather exposure could conceivably have aggravated his neuropathic pain, especially if he experienced symptoms of frostbite during that time." However, as this opinion is too general, based on the use of the language "could conceivably", and was not supported by any rationale, it cannot serve as the basis for an award of service connection. Id.

Additionally, even though the November 2020 opinion indicates a nexus between the Veteran's neuropathy and his exposure to cold weather in service, remand for an addendum opinion addressing such theory of entitlement is impermissible under the modernized review system. See 38 C.F.R. § 20.802. As the November 2020 VA opinion was submitted in July 2024, which is after the October 2020 rating decision on appeal, the Board finds no pre-decisional duty to assist error to warrant remand in this case.

Additionally, the Board acknowledges that the Veteran submitted articles in July 2024 in support of his claim. Medical treatise evidence can, in some circumstances, constitute competent medical evidence. See 38 C.F.R. § 3.159(a)(1) (competent medical evidence may include statements contained in authoritative writings such as medical and scientific articles and research reports and analyses). However, treatise evidence must "not simply provide speculative generic statements not relevant to the claim." Wallin v. West, 11 Vet. App. 509, 514. Instead, the treatise evidence, "standing alone," must discuss "generic relationships with a degree of certainty such that, under the facts of a specific case, there is at least plausible causality based upon objective facts rather than on an unsubstantiated lay medical opinion." Id.

Here, the articles do not pertain to the Veteran specifically. Although one of the articles suggests that exposure to certain toxins can cause peripheral neuropathy, the article does not consider the specific facts of the Veteran's case. Significantly, the article does not provide medical evidence that the Veteran's neuropathy was caused by his exposure to contaminated water at Camp Lejeune. The article lists specific toxins that can cause peripheral neuropathy, but there is no evidence that the Veteran has been exposed to any of the toxins listed in the article. In short, articles and treatises tend to be general in nature and tend not to relate to the specific facts in a given Veteran's claim. In the present case, the article submitted in July 2024 tends to fall into this general category. The Board acknowledges that the Veteran also submitted an article suggesting that there are certain personality traits in people with seborrheic dermatitis. However, this article does not indicate that the Veteran's neuropathy is related to his service or to a service-connected disability. As such, the Board finds that this information is not relevant as to the matter for consideration, and, therefore, is not probative to this case.

Moreover, following nerve studies conducted in March 2021, the interpretation was electrodiagnostic evidence of sensory peripheral neuropathy in the lower extremities and, notably, "no evidence of lumbar radiculopathy
the present case, the article submitted in July 2024 tends to fall into this general category. The Board acknowledges that the Veteran also submitted an article suggesting that there are certain personality traits in people with seborrheic dermatitis. However, this article does not indicate that the Veteran's neuropathy is related to his service or to a service-connected disability. As such, the Board finds that this information is not relevant as to the matter for consideration, and, therefore, is not probative to this case.

Moreover, following nerve studies conducted in March 2021, the interpretation was electrodiagnostic evidence of sensory peripheral neuropathy in the lower extremities and, notably, "no evidence of lumbar radiculopathy". As a result, the Board finds the evidence does not indicate that any of the Veteran's neurological symptoms are secondary to his service-connected degenerative arthritis of the spine.

The Veteran believes his neurological disability is related to his service, to include exposure to contaminated water and cold weather, and/or to his service-connected psychiatric and skin disabilities. The Veteran in this case is not competent to provide a nexus opinion regarding this issue. The issue is medically complex, as it requires knowledge of pathology and interpretation of complicated diagnostic medical testing. Therefore, it is outside the competence of the Veteran in this case because the record does not show that he has the medical training or credentials to make such a determination. Jandreau v. Nicholson, 492 F.3d 1372, 1377 n.4 (Fed. Cir. 2007); see also Kahana v. Shinseki, 24. Vet. App. 428 (2011). Consequently, the Board gives more probative weight to July 2017 and August 2017 VA examination reports and accompanying March 2020 addendum opinions.

In sum, the probative, competent evidence is against a finding that the Veteran's neurological disability, separate and distinct from his service-connected migraine headaches, is related to his service or is secondary to a service-connected disability. Accordingly, the benefit of the doubt doctrine is not applicable, service connection for a neurological disability is not warranted, and the claim must be denied. 38 U.S.C. § 5107; 38 C.F.R. § 3.102.

M. M. Celli

Acting Veterans Law Judge

Board of Veterans' Appeals

Attorney for the Board S. Morrad, Counsel

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.

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