Quartuccio v. Principi

Nicholas Quartuccio (plaintiff) served on active duty in the United States Army from 1977 to 1978. In 1994, Quartuccio initiated a claim with the Department of Veterans Affairs (the VA) (defendant) seeking disability benefits for paranoid schizophrenia, which he believed was connected to his service. In response to his claim, the VA sent Quartuccio a letter that informed him that he must submit evidence to show that his psychiatric condition was incurred or aggravated by his service or had existed continuously since his discharge. Medical evidence showed that Quartuccio currently did have schizophrenia, but the VA eventually denied his claim, finding no evidence of a service connection for his current disorder. In 2000, Quartuccio submitted a letter to the VA disputing the denial. In response, the VA sent Quartuccio a letter informing him that to reopen his claim he would have to submit new and material evidence. The VA found that he failed to meet this requirement and therefore did not reopen his claim. Quartuccio appealed to the Board of Veterans’ Appeals (the board). During this period, Congress passed the Veterans Claims Assistance Act (VCAA) to provide support and ensure fairness for veterans in the claims-adjudication process, which imposed new duties of notice on the VA. The board affirmed the VA’s decision that Quartuccio had failed to submit new and material evidence and also concluded that the two letters the VA had sent Quartuccio sufficiently satisfied the VCAA notice requirements.