10-41 726, 10-41 726

Veteran served on active duty June 1998–January 2007 and filed for service connection for headaches (claim filed May 2009).
RO denied the claim in December 2009; appeals and remands occurred in March 2013 and May 2015 for additional development and examinations.
Medical records show a current diagnosis of chronic headaches (first documented May 2009) and post-service reports that headaches began after an alleged in-service head injury (hitting head on an overhead bin and receiving stitches in 2005–2006).
Service treatment records (STRs) contain episodic complaints of headaches tied to upper respiratory infections and do not show a diagnosed chronic headache disorder or documentation of the alleged head injury/9 stitches.
Veteran failed to attend a VA examination scheduled for July 21, 2016, and provided no good cause; under 38 C.F.R. § 3.655 the claim was decided on the existing record.
No medical opinion in the record relates the Veteran’s current headaches to service; Board found lay statements about medical causation not competent to establish nexus.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Entitlement to service connection for headaches	Headaches began after an in-service head injury and continue to present	STRs do not show chronic headache or head injury; no medical nexus opinion; claimant missed VA exam	Denied — preponderance of evidence against service connection

Holton v. Shinseki, 557 F.3d 1362 (2010) (sets out elements required for service connection and nexus discussion)
Buczynski v. Shinseki, 24 Vet. App. 221 (2011) (Board may use silence in STRs as evidence when an injury would ordinarily be recorded)
Jandreau v. Nicholson, 492 F.3d 1372 (2007) (limits on lay competence for medical etiology opinions)
Bernard v. Brown, 4 Vet. App. 384 (1993) (appellate review may proceed when necessary development is complete)
Kahana v. Shinseki, 24 Vet. App. 428 (2011) (recognizes lay competence for some matters but not specialized medical etiology)