12-22 874, 12-22 874

Veteran served in the U.S. Army April 1966–November 1967; appeal from Houston RO decision (June 2011) with Board remand in Dec 2014.
Service-connected PTSD previously rated 50% and claimed for increase; multiple VA exams (2009, 2010, 2015, 2016) and treatment notes document symptoms including hypervigilance, nightmares, depression, substance abuse, auditory/visual hallucinations, suicidal ideation, impaired concentration, and reduced socialization.
Examiners variably found the Veteran capable of some household tasks and church attendance; some opinions noted intermittent inability to perform occupational tasks, but not continuous total impairment.
Wife’s 2017 lay statement reported constant nightmares, a prior suicide attempt, confusion while driving, inability to manage finances, and social isolation.
Board concluded PTSD symptomatology approximated criteria for a 70% rating (since March 21, 2007) but not 100%, and granted TDIU effective April 22, 2010 based on combined effects of PTSD and service-connected ankle disability.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether PTSD rating should exceed 50%	PTSD causes deficiencies in most areas (suicidal ideation, hallucinations, hypervigilance, impaired concentration) warranting ≥70% or 100%	Remaining functional abilities (household tasks, church attendance, coherent thought/speech) do not meet 100% criteria; some exams note ability to seek work	70% rating granted from March 21, 2007; 100% denied
Entitlement to TDIU	Veteran unable to secure or follow substantially gainful employment due to PTSD (short temper, poor concentration) and ankle disability	Veteran met schedular criteria earlier but continued working until 2010; functional evidence mixed but combined disabilities preclude substantially gainful employment after leaving work	TDIU granted effective April 22, 2010

Mauerhan v. Principi, 16 Vet. App. 436 (2002) (symptom lists in rating criteria are illustrative and permit consideration of similar manifestations and their occupational/social effects)
Esteban v. Brown, 6 Vet. App. 259 (1994) (prohibition on pyramiding; separate ratings allowed only for distinct, non-overlapping symptomatology)