## Facts

- Danny L. Mittleider, a Marine Corps Vietnam veteran, was granted service connection for PTSD.
- A VA regional office initially assigned a 30% PTSD rating, later increased to 50% effective July 2, 1990.
- Evidence before the Board included statements indicating the service-connected disability materially contributed to a serious employment handicap.
- The Board of Veterans’ Appeals denied a rating above 50%, finding PTSD caused “considerable” (not “severe”) social and industrial impairment under the then-applicable rating criteria.
- The record reflected comorbid conditions (including a personality disorder and substance-abuse issues), raising uncertainty as to which symptoms and functional limits were attributable to service-connected PTSD versus non-service-connected conditions.

## Issues

1. Whether the Board provided an adequate statement of reasons or bases for limiting PTSD to a 50% rating despite evidence suggesting more serious occupational impairment.
2. How VA must evaluate disability when medical evidence does not permit separating the effects of a service-connected condition from non-service-connected conditions.

## Decision

- The Court granted the Secretary’s motion to vacate the Board decision and remanded for readjudication.
- The Court required the Board on remand to address the apparent inconsistency between evidence of serious employment impact and the Board’s “considerable” impairment finding.
- The case is cited for the rule that when symptom effects cannot be medically distinguished between service-connected and non-service-connected conditions, VA must attribute the overlapping symptoms to the service-connected disability under the reasonable-doubt standard.

## Legal Principles

- The Board must provide reasons or bases sufficient to permit understanding of the decision and judicial review, including reconciling materially conflicting evidence in the record. (38 U.S.C. § 7104(d)(1))
- When medical evidence cannot separate the effects of a service-connected disability from a non-service-connected condition, VA must resolve reasonable doubt in the claimant’s favor and treat all inseparable signs and symptoms as part of the service-connected disability for rating purposes. (38 U.S.C. § 5107(b); 38 C.F.R. § 3.102)
- In cases involving mental-disorder ratings and comorbid diagnoses, VA must either obtain clarification sufficient to distinguish symptom sources or rate in a manner consistent with the reasonable-doubt rule when differentiation is not possible.

## Conclusion

The Court vacated and remanded because the Board did not adequately explain its rating determination in light of evidence indicating serious occupational impairment, and the case is widely applied for the rule that inseparable symptom effects must be attributed to the service-connected disability under the benefit-of-the-doubt doctrine.


Mittleider v. West, 11 Vet. App. 181 (1998)