13-17 742, 13-17 742

Veteran served active duty Jan 1993–Jan 1997 (plus Reserve service); filed VA claims in Apr 2011 and Jun 2013; appeals from RO Nashville decisions.
Service records show right wrist sprain/tendonitis treated in 1996 and reported at separation; Veteran and a buddy state wrist symptoms from 1996 onward.
VA examinations: May 2011 (no etiological opinion), Aug 2015 (could not state ≥50% probability), Dec 2016 (chronic right wrist sprain diagnosed since 1996 but negative etiology opinion without adequate rationale).
Service records show scoliosis noted on enlistment (1992) and no documented back complaints, treatment, or diagnosis during service or for many years after; first reported back disability is the 2011 claim.
Dec 2016 imaging showed mild degenerative disc disease; examiner concluded scoliosis is a congenital defect and degenerative changes were not incurred in or due to service.
Board remanded previously (Apr 2015, Nov 2016); Board found VA satisfied duty to assist and proceeded to adjudicate.

Issue	Veteran's Argument	VA/Defendant's Argument	Held
Service connection — right wrist	Right wrist sprain/tendonitis began in service (1996) and continued since	VA examiners provided inconclusive or negative nexus opinions; some opinions lacked full rationale or review of records	Granted — evidence in equipoise; service treatment + current diagnosis support connection
Service connection — back disability	Back disability (from loading trucks) began in service	Service records show scoliosis on enlistment and no in-service or post-service back complaints/treatment; VA exams find no in-service injury or superimposed disease; degenerative disease first appears decades later	Denied — scoliosis treated as congenital defect; no evidence of in-service incurrence or superimposed injury; preponderance against claim

Holton v. Shinseki, 557 F.3d 1362 (Fed. Cir.) (elements for direct service connection)
O'Bryan v. McDonald, 771 F.3d 1376 (Fed. Cir.) (distinguishing congenital defects from congenital diseases)
Quirin v. Shinseki, 22 Vet. App. 390 (Ct. Vet. App.) (analysis of congenital disease vs defect and service connection)
Jandreau v. Shinseki, 492 F.3d 1372 (Fed. Cir.) (lay evidence limits on medical etiology opinions)
Gilbert v. Derwinski, 1 Vet. App. 49 (Ct. Vet. App.) (benefit-of-the-doubt rule standard)
Stegall v. West, 11 Vet. App. 268 (Ct. Vet. App.) (requirement of substantial compliance with remand instructions)
Ortiz v. Principi, 274 F.3d 1361 (Fed. Cir.) (clarifying benefit-of-the-doubt application)
Winn v. Brown, 8 Vet. App. 510 (Ct. Vet. App.) (congressional/administrative guidance on congenital conditions)