## Facts

- James Groves served on active duty in the U.S. Army from 1969 to 1972 and again from 1974 to 1979.
- In 1979, while on active duty, Groves experienced an acute psychotic episode and received a diagnosis of paranoid schizophrenia.
- A few months later, at discharge, Groves was diagnosed with a personality disorder rather than schizophrenia.
- In 1981, Groves was hospitalized twice and treated for paranoid schizophrenia and schizoaffective disorder.
- Groves filed a claim with the Department of Veterans Affairs (VA) seeking disability compensation based on service connection for his psychiatric condition.
- In 1982, the VA confirmed a diagnosis of paranoid schizophrenia but denied service connection, stating that Groves had not shown a link between his then-current condition and his military service (including because the in-service schizophrenia diagnosis was not accepted as establishing the required connection).
- Groves’s psychiatric disability continued, and in 2000 he asked the VA to reopen his claim.
- The VA later granted service connection for schizophrenia, but set the effective date in 2000 rather than back to the original claim.
- Groves sought an earlier effective date, arguing the 1982 denial was clearly and unmistakably erroneous because the law governing chronic diseases did not require an additional medical nexus opinion once chronic schizophrenia in service and later schizophrenia were shown.
- The Board of Veterans’ Appeals and the U.S. Court of Appeals for Veterans Claims rejected Groves’s argument, reasoning that the 1982 record lacked medical evidence linking the in-service and post-service schizophrenia diagnoses.
- Groves appealed to the U.S. Court of Appeals for the Federal Circuit.

## Issues

1. Whether, under the law governing service connection for chronic diseases, the Board and the Veterans Court erred by requiring separate medical nexus evidence to connect Groves’s in-service schizophrenia and his later schizophrenia.
2. Whether that legal error affected the analysis of Groves’s request for an earlier effective date based on alleged clear and unmistakable error in the 1982 VA denial.

## Decision

- The Federal Circuit reversed the Veterans Court’s decision and remanded for further proceedings.
- The court held that, for a chronic disease shown in service (including psychoses such as schizophrenia), later manifestations of the same disease may be service connected without a separate medical nexus opinion, absent evidence of an intercurrent cause.
- Because the lower tribunals demanded additional nexus evidence contrary to the chronic-disease rule, their legal analysis was incorrect and required reconsideration on remand.

## Legal Principles

- Service connection may be established by showing that a disability began in service or is otherwise related to service.
- For conditions treated as “chronic diseases” under VA law and regulation, the chronicity provisions (commonly applied through 38 C.F.R. § 3.303(b)) can provide the link between service and a later diagnosis when the same chronic disease is shown in service and again later.
- When chronicity in service is established and the same condition appears after service, VA generally may not require a separate medical opinion to prove a causal link, unless the later condition is clearly due to an intercurrent cause.
- In disputes over whether a prior final VA decision was legally wrong for purposes of retroactive relief (including arguments framed as clear and unmistakable error), courts review whether the correct legal standard was applied, including whether the agency demanded proof the law does not require.

## Conclusion

Groves v. Peake held that the chronic-disease rule can supply the service-connection link for schizophrenia when schizophrenia is shown in service and appears again after service, so the Board and the Veterans Court erred by insisting on additional medical nexus evidence; the Federal Circuit reversed and remanded for proceedings consistent with that rule, with potential consequences for the effective date of Groves’s awarded benefits.


Groves v. Peake, 524 F.3d 1306 (2008)