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
What this means for you
A denial is a starting point, not the end of the road. You can see why this claim fell short — and, if you are still inside the one-year window, the appeal lanes that may remain open to you.
What you can do next
Related decisions
Other Board decisions on a similar condition or argued the same way.
- 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).
- Remanded (sent back)
The Board remands the claims for service connection for various conditions, including migraines, cubital tunnel syndrome, angioneurotic edema, and hand/finger conditions, due to inadequate VA opinions.
- Granted
The Board granted service connection for obstructive sleep apnea, effective from the date of the February 2025 rating decision.
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