## Facts

- William N. Clemons, a U.S. Navy veteran (1951–1958) with combat-related service, sought VA disability compensation for a psychiatric condition, listing “posttraumatic stress disorder (PTSD)” on his claim.
- Service treatment records reflected in-service treatment for anxiety.
- VA-developed evidence (including examinations and treatment records) did not show a clear PTSD diagnosis under applicable criteria; instead, it reflected diagnoses including schizoid personality disorder and an anxiety disorder with PTSD features.
- The Regional Office denied the claim for lack of a substantiated PTSD diagnosis.
- The Board of Veterans’ Appeals affirmed, treating the matter as limited to PTSD and not addressing whether other psychiatric diagnoses shown in the record could be service connected.
- Clemons appealed to the U.S. Court of Appeals for Veterans Claims, asserting that the claim reasonably encompassed an acquired psychiatric disorder beyond PTSD.

## Issues

1. When a veteran files for service connection identifying a specific mental disorder (e.g., PTSD), must VA construe the claim as limited to that diagnosis, or as including any psychiatric disability reasonably encompassed by the claimant’s description, symptoms, and record evidence?
2. Whether the court had jurisdiction, on review of a Board decision denying “PTSD,” to require consideration of other acquired psychiatric disorders reasonably raised by the record.

## Decision

- The court held that a claim labeled as PTSD is not confined to that diagnostic label and includes any mental disability reasonably encompassed by the claimant’s description, reported symptoms, and record information.
- The court rejected the view that non-PTSD diagnoses required a separate, newly filed claim when the evidence indicated they were part of the same sought benefit for a psychiatric disability related to service.
- The court concluded it had jurisdiction because the broader acquired-psychiatric-disorder question was part of the same claim the Board decided, even if the Board characterized it narrowly.
- The court set aside the Board’s December 6, 2006 decision and remanded for readjudication consistent with this construction of claim scope.

## Legal Principles

- A veteran’s lay identification of a mental-disorder diagnosis does not legally limit the claim to that diagnosis; veterans are competent to report symptoms but generally not to supply accurate medical diagnoses.
- The scope of a mental-disorder service-connection claim includes any mental disability reasonably encompassed by the claimant’s description of the claim, reported symptoms, and evidence obtained or submitted.
- In the nonadversarial VA benefits system, VA and the Board must broadly construe filings and adjudicate reasonably raised theories of entitlement, consistent with the duty to assist.
- On judicial review, the court may address the proper scope of the claim where the Board’s decision resolves the underlying benefits request but mischaracterizes it by an overly narrow diagnostic label.

## Conclusion

The court required VA to treat a PTSD-labeled claim as a claim for any acquired psychiatric disorder reasonably raised by the veteran’s symptoms and the record, vacated the Board’s denial that focused only on the absence of a PTSD diagnosis, and remanded for readjudication under the correct scope-of-claim rule.


Clemons v. Shinseki, 23 Vet. App. 1 (2009)