Back to BVA DecisionsDENIEDSpecial Benefit NO SPECIAL BENEFIT Docket No. 251107-592972
MIGRAINE
D. JOHNSON · 2026 · Case ID: A26033602
Summary
The Veteran, who served from January 1968 to January 1970, appeals the denial of service connection for acute intermittent tension headaches, claimed as migraines, secondary to his service-connected hypertension. The Board reviewed the evidence of record, noting that service treatment records and private medical records were silent for headache complaints, with only a November 2014 VA treatment record indicating a complaint of erratic muscle contraction headaches. A January 2023 VA examination for hypertension found no complications related to the condition. A subsequent April 2024 VA examination diagnosed acute intermittent tension headaches, with the Veteran reporting occasional headaches and elevated blood pressure. The VA examiner opined in May 2025 that the migraines were less likely than not due to or aggravated by hypertension, citing the multifactorial pathogenesis of tension headaches, genetic influences, and the lack of a clear causal link to hypertension or its treatment. The examiner also stated that the condition was less likely than not caused by TERAs, including herbicide exposure, as medical literature did not demonstrate a causal relationship. The Board found the VA examiner's opinions probative and persuasive, noting they were based on medical literature and rationales. The Board afforded no weight to the Veteran's submitted medical articles, finding them general in nature and not combined with a medical professional's opinion specific to the Veteran's case. The Board concluded that the evidence weighed against service connection, and the benefit-of-the-doubt doctrine was not applicable as the evidence was not in approximate balance. Service connection for acute intermittent tension headaches was denied.
Rationale
Service treatment records silent for headache complaints.; Private medical records silent for headache complaints.; VA examiner opined less likely than not related to or aggravated by hypertension.; Board found VA examiner's opinion probative and persuasive.; Medical literature did not demonstrate causal relationship between tension headaches and herbicide exposure.; Evidence weighed against finding condition due to or aggravated by service or service-connected disability.
Full Decision Text
Citation Nr: A26033602 Decision Date: 04/10/26 Archive Date: 04/10/26 DOCKET NO. 251107-592972 DATE: April 10, 2026 ORDER Entitlement to service connection for acute intermittent tension headaches (claimed as migraines) is denied. FINDING OF FACT The Veteran's acute intermittent tension headaches are not secondary to service-connected hypertension, and are not otherwise related to an in-service injury or disease. CONCLUSION OF LAW The criteria for service connection for acute intermittent tension headaches (claimed as migraines) are not met. 38 U.S.C. §§ 1110, 5107; 38 C.F.R. §§ 3.102, 3.310. REASONS AND BASES FOR FINDING AND CONCLUSION The Veteran had active service from January 1968 to January 1970. This matter was previously before the Board in May 2025 and remanded for further development. The rating decision on appeal was issued in August 2025. In the November 2025 VA Form 10182, Decision Review Request: Board Appeal (Notice of Disagreement), the Veteran elected the Hearing docket. On December 11, 2025, the Veteran, through his representative, withdrew the hearing request. Therefore, the Board may only consider the evidence of record at the time of the August 2025 agency of original jurisdiction (AOJ) decision on appeal, as well as any evidence submitted by the Veteran or representative within 90 days following receipt of the withdrawal of the hearing request. 38 C.F.R. § 20.302(b). If evidence was submitted either (1) during the period after the AOJ issued the decision on appeal and prior to receipt of the withdrawal, or (2) more than 90 days following receipt of the withdrawal, the Board did not consider it in its decision. 38 C.F.R. §§ 20.300, 20.302(b), 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. Entitlement to service connection for acute intermittent tension headaches (claimed as migraines) is denied. The Veteran seeks service connection for migraines secondary to his service-connected hypertension. Service connection may be granted for disability resulting from disease or injury incurred in or aggravated by active service. 38 U.S.C. §§ 1110, 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 be granted for a disability that is due to, or aggravated by, service-connected disease or injury. 38 C.F.R. § 3.310. The August 2025 rating decision on appeal includes favorable findings that: (1) the Veteran's claimed primary disability of hypertension is service connected; (2) he has a current diagnosis of acute intermittent tension headaches; and (3) participation in a toxic exposure risk activity (TERA) is conceded based on the Veteran's exposure to an herbicide agent - 2,3,7,8 - Tetrachlorodibenzodioxin (TCDD) during service in Vietnam. The Board is bound by these favorable findings. 38 C.F.R. § 3.104 (c). Turning to the evidence of record, service treatment records are silent for complaints, symptoms, or treatment for a headache condition. In a January 1970 Report of Medical History for separation, the Veteran denied frequent or severe headaches. A January 1970 Report of Medical Examination indicates a normal clinical evaluation. Post discharge, VA treatment records dated in April 2005 and September 2005 indicate the Veteran denied headaches. Private treatment records dated in February 2009 and April 2009 indicate the Veteran denied headaches. A September 2009 VA treatment record indicates the Veteran denied headaches. A November 2014 VA treatment Board is bound by these favorable findings. 38 C.F.R. § 3.104 (c). Turning to the evidence of record, service treatment records are silent for complaints, symptoms, or treatment for a headache condition. In a January 1970 Report of Medical History for separation, the Veteran denied frequent or severe headaches. A January 1970 Report of Medical Examination indicates a normal clinical evaluation. Post discharge, VA treatment records dated in April 2005 and September 2005 indicate the Veteran denied headaches. Private treatment records dated in February 2009 and April 2009 indicate the Veteran denied headaches. A September 2009 VA treatment record indicates the Veteran denied headaches. A November 2014 VA treatment record indicates a complaint of erratic muscle contraction headaches. VA treatment records dated in December 2014 and May 2018 indicate that reviews of the Veteran's neurological system revealed no headaches. VA treatment records dated from June 2018 to October 2023 are silent for complaints, symptoms or treatment for any headache condition. In January 2023, the Veteran was afforded a VA contract examination for hypertension. The examiner indicated that the Veteran has had a diagnosis of hypertension since 1970 and did not have any other pertinent physical findings, complications, conditions, signs or symptoms related to his condition. The Veteran reported his current symptom was elevated blood pressure; he did not report any other symptoms. Private treatment records dated in January 2024, May 2024, and September 2024 indicate that reviews of the Veteran's neurological system were negative for headaches. In April 2024, the Veteran was afforded a VA contract examination for headaches. He reported his condition onset about the time he was diagnosed with hypertension and specified the year 1981. He reported that he noticed occasional headaches and that his blood pressure was elevated with a headache. He also reported he occasionally will have an increase in blood pressure and then notices a headache. He reported he used Tylenol, as needed, for his headaches. The examiner diagnosed acute intermittent tension headaches. VA treatment records dated from July 2024 to March 2025 are silent for complaints, symptoms or treatment for any headache condition. In a May 2025 VA addendum opinion, the examiner opined that the Veteran's claimed migraines were less likely than not due to or the result of his service-connected hypertension. As a rationale, the examiner stated that the pathogenesis of Tension Type Headaches (TTHs) is probably multifactorial, but the precise mechanisms are not known; that TTHs are partially explained by increased sensitivity to pain with the activation of hyperexcitable peripheral afferent neurons from head and neck muscles; and that muscle tenderness and psychological tension are associated with and aggravate TTHs but are not clearly its cause. The examiner also stated that susceptibility to TTHs is influenced by genetic factors, and that the mean lifetime prevalence of TTHs in adults is 46%, with prevalence peaking at age 40-49 years in both sexes. Further, the examiner stated that while the Veteran is competent to report symptoms, he is not medically qualified to self-diagnose or determine causation, and the etiology of acute intermittent tension headaches (evidenced by medical literature) does not support that it is caused by the Veteran's hypertension. The examiner also stated that while uncontrolled hypertension can present with a symptom of headache, uncontrolled hypertension headache symptoms are separate and unrelated to the Veteran's diagnosis of acute intermittent tension headaches. The examiner stated that hypertension and acute intermittent tension headaches are not medically related and are separate entities. The May 2025 VA examiner opined that the Veteran's claimed migraines were less likely than not aggravated by his hypertension. As a rationale, the examiner stated that the Veteran treated his tension headaches with over-the-counter Tylenol as needed; that this level of pharmacotherapy did not constitute an aggravation of the condition as it is a medically standard treatment; and that there was no evidence to support hypertension or medication taken for treatment of that condition would impact the treatment of the claimed headaches. The examiner stated that the severity of the claimed headache condition was not impacted by the service-connected hypertension or its treatment. The May 2025 VA examiner further opined that the claimed headache condition was less likely than not caused by the indicated TERAs, after considering the total potential exposure through all applicable military deployments of the Veteran and the synergistic, combined effect of all TERAs of the Veteran. As a rationale, the examiner restated the rationale supporting the negative nexus opinion for secondary service connection. Further, the examiner stated that a thorough analysis of peer-reviewed medical literature and the known etiology of the diagnosed condition failed to demonstrate a causal relationship between acute intermittent tension headaches and Herbicide Agent - 2,3,7 claimed headaches. The examiner stated that the severity of the claimed headache condition was not impacted by the service-connected hypertension or its treatment. The May 2025 VA examiner further opined that the claimed headache condition was less likely than not caused by the indicated TERAs, after considering the total potential exposure through all applicable military deployments of the Veteran and the synergistic, combined effect of all TERAs of the Veteran. As a rationale, the examiner restated the rationale supporting the negative nexus opinion for secondary service connection. Further, the examiner stated that a thorough analysis of peer-reviewed medical literature and the known etiology of the diagnosed condition failed to demonstrate a causal relationship between acute intermittent tension headaches and Herbicide Agent - 2,3,7,8 - TCDD. Within 90 days following receipt of the withdrawal of the hearing request, the Veteran submitted an April 2016 journal article that concluded that the presence of nonspecific headache in hypertensive patients has a "paradoxical significance" in that it is associated with a high-risk profile but does not result in a worse prognosis over the long term. The Board concludes that, while the Veteran has a current diagnosis of acute intermittent tension headaches, the evidence of record persuasively weighs against finding that the Veteran's claimed headache condition is due to or the result of, or aggravated by service or a service-connected disability. 38 U.S.C. §§ 1110, 1131; Allen v. Brown, 7 Vet. App. 439 (1995) (en banc); 38 C.F.R. §§ 3.303, 3.310(a). In this regard, the Board finds the May 2025 VA examiner's opinions probative. The opinions are based on consideration of the lay contentions, a review of the Veteran's medical history and other relevant VA documents, and are supported by sufficient rationales. Nieves-Rodriguez v. Peake, 22 Vet. App. 295, 304 (2008). There is no contradictory medical opinion in the record. The Board has considered the April 2016 medical journal article submitted by the Veteran's attorney representative. The Board also notes that the attorney representative cited to, but did not submit, a 2023 article described as establishing an association between hypertension and migraines and severe headaches. A medical article "can provide important support when combined with an opinion of a medical professional" if the medical article evidence discussed 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. Sacks v. West, 11 Vet. App. 314 (1998); see also Wallin v. West, 11 Vet. App. 509 (1998) (medical treatise evidence discussed generic relationships with a degree of certainty to establish a plausible causality of nexus). Here, however, the articles relied on by the Veteran's representative are not combined with an opinion of a medical professional and the information in the article does not specifically relate to the facts and circumstances of the Veteran's case. Rather, the information is general in nature. As such, the Board affords the April 2016 and 2023 articles no probative weight. The Veteran may believe that his claimed headache condition is due to service, or is due to or the result of or aggravated by his service-connected hypertension. The Veteran in this case, however, is not competent to provide a nexus opinion regarding this issue. Determining the etiology of headaches requires medical expertise. 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 must rely on the competent and probative VA medical nexus opinion. In sum, the criteria for service connection for acute intermittent tension headaches (claimed as migraines) have not been established. The Board has considered the applicability of the benefit-of-the-doubt doctrine; however, the evidence is not in approximate balance or nearly equal. Hence, that doctrine is not applicable. 38 U.S.C. § 5107 (b); 38 C.F.R. § 3.102; Gilbert v. Derwinski, 1 Vet. App. 49, 53-56 (1990). Service connection for intermittent tension headaches (claimed as migraines) is not warranted. D. JOHNSON Veterans Law Judge Board of Veterans' Appeals Attorney for the Board M.T. The Board's decision in this case is binding only with respect to the instant matter The Board has considered the applicability of the benefit-of-the-doubt doctrine; however, the evidence is not in approximate balance or nearly equal. Hence, that doctrine is not applicable. 38 U.S.C. § 5107 (b); 38 C.F.R. § 3.102; Gilbert v. Derwinski, 1 Vet. App. 49, 53-56 (1990). Service connection for intermittent tension headaches (claimed as migraines) is not warranted. D. JOHNSON Veterans Law Judge Board of Veterans' Appeals Attorney for the Board M.T. 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.