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Board of Veterans' Appeals · Legacy series

Entitlement to a rating in excess of 10 percent for left knee degenerative joint disease is remanded.

January 30, 2026Citation Nr. 26001437Docket 16-58 287va.gov source

  • left knee degenerative joint disease rating in excess of 10 percentRemanded
  • left knee limitation of extension compensable ratingRemanded
  • lateral instability of the left knee rating in excess of 10 percent prior to October 5, 2021Remanded
  • patellar instability of the left knee rating in excess of 20 percent from October 5, 2021Remanded
DecisionAnalysis

Board reasoning

The Board remands for further development per substantial compliance requirements. It notes prior Board and Court actions, including JMPR vacatur, and emphasizes the need for an addendum opinion addressing extension with repeated use over time and during flare-ups, consistent with Ingram and Stegall. The opinion must explain any inability to provide estimates and ensure all evidence added since the September 2025 SOC is considered before readjudication.

Issues

  • left knee degenerative joint disease rating in excess of 10 percentRemanded
  • left knee limitation of extension compensable ratingRemanded
  • lateral instability of the left knee rating in excess of 10 percent prior to October 5, 2021Remanded
  • patellar instability of the left knee rating in excess of 20 percent from October 5, 2021Remanded

Authorities

  • Stegall v. West, 11 Vet. App. 268Address remand compliance and necessity of following remand orders.
  • Ingram v. Collins, 38 Vet. App. 130Guide for providing extension/flexion estimates over time and during flare-ups.

Extracted with gpt-5-nano-2025-08-07. Citations are kept only when they appear in the decision text.