⚖ Oral Arguments, with Context

The Court of Appeals for Veterans Claims considers which benefits claims were before the Board in Jacqueline Roberson's appeal for her late husband. He sought compensation under Section 1151 for a heart condition and pressure ulcers after VA treatment, and a total disability rating based on individual unemployability, or TDIU. Section 1151 can compensate certain additional disabilities caused by VA care as if service connected. TDIU can pay at the total-disability rate when service-connected disabilities prevent substantially gainful work. Roberson will argue that medical evidence linking the heart and ulcer conditions to cocaine use associated with his PTSD brought secondary service connection into the claims. Secondary service connection covers a condition caused or aggravated by an already service-connected disability. She will also argue that an unresolved 2004 PTSD appeal affects the TDIU period. The Secretary will contend that Section 1151 and service-connection claims are separate, while agreeing that the Board must reconsider TDIU from February 1, 2011.

Jacqueline Roberson v. Douglas A. Collins (No. 24-5809) — United States Court of Appeals for Veterans Claims, argued July 16, 2026.