Martin v. McDonald, 669 F. App'x 566

Grover Martin, an Army veteran (1988–1990), sought service connection for a psychiatric condition including PTSD; initial VA denial occurred in 1998.
Martin successfully reopened the claim and in April 2011 the Board remanded it to the regional office (RO) with instructions to issue a new decision if benefits were not granted.
Martin filed a mandamus petition in the Court of Appeals for Veterans Claims in February 2016 seeking expedited RO action, alleging delay.
The Veterans Court ordered a response; four days later (March 11, 2016) the RO issued a decision denying the claim; the Secretary notified the Veterans Court the remand had been adjudicated.
The Veterans Court dismissed Martin’s mandamus petition as moot; Martin appealed to the Federal Circuit, but did not challenge the mootness dismissal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether this court has jurisdiction to review the Veterans Court’s dismissal of the mandamus petition	Martin sought reversal of VA denial and alleged due process violations (altered records, inconsistent Board findings), and asked the court to order benefits	The Veterans Court dismissed the mandamus petition as moot after the RO issued a decision; the proper route to contest the benefits denial is the ordinary VA appeals process	Dismissed for lack of jurisdiction: plaintiff did not contest the Veterans Court’s mootness ruling and seeks relief (reversal of benefits denial) that must be pursued through the regular administrative/appeal process

Lamb v. Principi, 284 F.3d 1378 (Fed. Cir. 2002) (standards for mandamus relief from Veterans Court denial)
Kerr v. U.S. Dist. Court, 426 U.S. 394 (1976) (mandamus requires clear right and lack of alternative remedies)
Cheney v. U.S. Dist. Court for D.C., 542 U.S. 367 (2004) (mandamus is not a substitute for regular appeals; alternative adequate remedies bar writ)