CONYERS v. MCDONOUGH , No. 23-1525 (Fed. Cir. 2024)
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In this case before the United States Court of Appeals for the Federal Circuit, Vincent Curtis Conyers, an army veteran, sought employment benefits under the Veteran Readiness and Employment program, which is administered by the United States Department of Veterans Affairs. His application was denied by the VA, and this denial was subsequently upheld by the Board of Veterans' Appeals and the United States Court of Appeals for Veterans Claims. During his appeal, Mr. Conyers requested that certain documents be added to the administrative record under the doctrine of constructive possession. The Veterans Court denied his request, reasoning that the documents did not have a "direct relationship" to his claim, a standard of review that the court derived from a previous decision in Euzebio v. Wilkie.
However, the United States Court of Appeals for the Federal Circuit held that the Veterans Court applied an erroneous legal standard in its review of the doctrine of constructive possession. The Federal Circuit stated that the correct standard for constructive possession is one of "relevance and reasonableness," not the "direct relationship" standard applied by the Veterans Court. The Federal Circuit noted that its standard aligns with the VA's statutory duty to assist veterans in substantiating their claims and ensures that all record documents reasonably expected to be part of a veteran’s claim are included in the administrative record. Therefore, the court vacated the decision of the Veterans Court and remanded it for further proceedings, with the instruction to apply the correct standard of "relevance and reasonableness" in its review of the doctrine of constructive possession.
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