The Board denied the Veteran's motion for revision based on clear and unmistakable error of the August 25, 1971 Rating Decision denying service connection for angioneurotic edema, finding the decision was subsumed by the November 14, 1989 Board decision and therefore not subject to collateral attack. The Board also denied an effective date prior to January 11, 2011 for any award of service connection.
The deciding factor: The Board applied the doctrine of 'subsuming' to conclude that because the November 14, 1989 Board decision addressed the same issue on the same factual basis as the August 25, 1971 Rating Decision, the latter decision could not be subject to collateral attack based on clear and unmistakable error.
- Claimed conditions
- angioneurotic edema
- How they argued it
- Direct service connection
- Exposure basis
- None
- Rating assigned
- None in this decision
- Decision date
- November 13, 2025
- Citation
- A25098716
Veterans Law Judge
Decisions by this judge: 1,455 · Granted: 23% (granted or partly granted, in the vetted decisions on this site)
Judge attribution: 2025 complete; earlier years partial.
This is a plain-language summary generated by AI from a public Board of Veterans’ Appeals decision. It can contain errors — always verify against the original. Look up the original decision on VA.gov (opens in a new tab) using citation A25098716.
What this means for you
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What you can do next
Related decisions
Other Board decisions on a similar condition or argued the same way.
- Denied
The Board denied the Veteran's claim for service connection for a skin disability other than tinea pedis, finding that there was no persuasive evidence of such a condition during or proximate to his military service. The appeal is dismissed.
- Denied
The Board denied an effective date prior to July 19, 2023 for the grant of service connection for angioneurotic edema.
- Partly granted
The Board granted service connection for angioneurotic edema but denied it for chronic fatigue syndrome (CFS).
- Partly granted
The Board granted service connection for angioneurotic edema and remanded the claim for a compensable rating for allergic rhinitis.
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