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Hamilton v. Brown
39 F.3d 1574 (Fed. Cir.1994) ; Clearinghouse Number: 50633
Description
Veterans Who Filed Initial Notices of Disagreement with VA Denials Before 1988 Are Not Entitled to Court of Veterans Appeals Hearings
Abstract
The Federal Circuit has held that appellant veterans, who filed
multiple Notices of Disagreement (NODs), are not entitled to review
of their claims in the Court of Veterans Appeals (CVA). NODs are
the vehicle by which veterans announce to the Department of
Veterans Affairs (VA) their intention to appeal administratively
the adverse initial determinations on their claims. Effective
September 1, 1989, Congress established CVA to provide for the
first time a judicial appeals process for veterans benefits
matters. Because of the large numbers of pending administrative
appeals and concern that CVA would be overwhelmed initially,
Congress limited CVA jurisdiction to those matters in which an NOD
had been filed on or after November 18, 1988. Each of the
appellants had filed both pre- and post-1988 NODs with respect to a
particular benefits claim that had been pending in the
administrative review process before 1988. Appellants claimed that
they were entitled to CVA review of their claims because their most
recent NODs had been filed after the 1988 deadline. CVA
consolidated appellants’ appeals and held that the NOD
referred to in section 402 of Veteran’s Judicial Review Act,
31 U.S.C. § 7105, is the NOD that initiates the administrative
appeal for a particular claim. Since the NODs relied upon by
appellants to establish CVA jurisdiction had initially been filed
before the 1988 deadline, the court held that it had no
jurisdiction to hear appellants’ claims. Affirming, the
Federal Circuit held that the single-NOD rule is supported by, or
at least not inconsistent with, the plain language of the statute
and its legislative history.
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