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Consideration of Pain and Other Factors in Rating Disabilities

By Ronald B. Abrams & Meg Bartley

Veterans who are service connected for musculoskeletal disabilities often experience limitation of motion and pain caused by their service-connected conditions. In DeLuca v. Brown, the U.S. Court of Veterans Appeals addressed the issue of whether pain and weakness in plaintiff's left arm, caused by a service-connected muscoloskeletal condition, should be considered in addition to the limitation of motion caused the by the left-arm condition.

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