Murphy v. Wilkie, 983 F.3d 1313

David Murphy, Army veteran (1971–1974), has long sought VA disability benefits for psychiatric conditions; privately diagnosed with paranoid-type schizophrenia in 1982.
He first filed for PTSD in 2003 (denied); between 2006–2012 he filed multiple reopen requests for PTSD and schizophrenia, all denied as lacking nexus or new/material evidence.
In February 2012 Murphy filed a Request to Reopen (2012 RTR) that listed only PTSD; a VA exam found schizophrenia but not PTSD, and the RO denied reopening PTSD.
Murphy filed a Notice of Disagreement and a Form 9 (2013) that mentioned both PTSD and schizophrenia; the RO later treated the Form 9 as seeking to reopen schizophrenia and issued a July 2014 denial of reopening for schizophrenia (Murphy did not appeal that specific denial).
The Board addressed Murphy’s PTSD appeal and concluded it lacked jurisdiction over schizophrenia because that issue had been subject to a prior final denial; the Veterans Court affirmed (applying Boggs and alternatively Clemons).
The Federal Circuit held Clemons’ lenient claim‑scope rule applies to requests to reopen but affirmed on the Veterans Court’s alternative holding that Murphy’s February 2012 RTR did not reasonably encompass reopening the schizophrenia claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Clemons’ lenient, pro‑veteran claim‑scope rule applies to requests to reopen	Clemons should govern; VA must sympathetically read pro se reopen requests to include conditions the veteran reasonably expected to include	Boggs governs reopenings: finality concerns require treating separately diagnosed conditions as distinct claims when reopening	Clemons applies to reopen requests as an aspect of VA’s duty to sympathetically develop claims; Boggs does not foreclose Clemons’ rule
Whether Murphy’s 2012 RTR reasonably encompassed schizophrenia such that the Board had jurisdiction	Murphy argues his filings later referenced schizophrenia and VA should have treated the 2012 RTR as encompassing it	VA and Veterans Court: given prior final decisions and later filings showing Murphy understood claims were separate, 2012 RTR did not reasonably encompass schizophrenia	Held Murphy’s 2012 RTR did not reasonably include schizophrenia; Board lacked jurisdiction over schizophrenia claim in that appeal

Boggs v. Peake, 520 F.3d 1330 (Fed. Cir. 2008) (separately diagnosed diseases constitute separate claims for purposes of reopening/finality)
Clemons v. Shinseki, 23 Vet. App. 1 (Vet. App. 2009) (VA must liberally construe pro se claim scope by veteran’s reasonable expectations)
Hodge v. West, 155 F.3d 1356 (Fed. Cir. 1998) (VA must fully and sympathetically develop veterans’ claims)
Roberson v. Principi, 251 F.3d 1378 (Fed. Cir. 2001) (VA must determine all potential claims raised by the evidence regardless of label)
Shea v. Wilkie, 926 F.3d 1362 (Fed. Cir. 2019) (scope of pro se claimant’s claim can be inferred from evidence to which filings point)
Sellers v. Wilkie, 965 F.3d 1328 (Fed. Cir. 2020) (claims must identify condition at least at a high level; VA duty to assist attaches once VA comprehends the claim)