Dorsett and Repatriation Commission (Veterans' entitlements) [2018] AATA 2241 (12 July 2018)
Division:VETERANS' APPEALS DIVISION
File Number(s): 2015/2219
Re:Phillip Dorsett
APPLICANT
AndRepatriation Commission
RESPONDENT
DECISION
Tribunal:Deputy President Dr P McDermott RFD
Date:12 July 2018
Place:Brisbane
The decision under review is affirmed.
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Deputy President Dr P McDermott RFD
CATCHWORDS
VETERANS’ AFFAIRS – application for special rate of pension – conditions of post-traumatic stress disorder and alcohol dependence – whether non-accepted conditions prevented the applicant from undertaking employment – whether other factors prevented the applicant from undertaking employment – alone test not satisfied – ameliorating provisions not satisfied – decision affirmed
LEGISLATION
Veterans’ Entitlement Act 1986 (Cth)
CASES
Sheehy v Repatriation Commission [1996] FCA 1516
Repatriation Commission v Richmond [2014] FCAFC 124
Repatriation Commission v Hendy (2002) 76 ALD 47
Repatriation Commission v Watkins [2015] FCAFC 10
Beezley v Repatriation Commission [2015] FCAFC 165
Summers v Repatriation Commission [2015] FCAFC 36
Owen v Repatriation Commission (1995) FCA 1428
Repatriation Commission v Butcher [2007] FCAFC 36; (2007) 94 ALD 364
Smith v Repatriation Commission [2014] FCAFC 53; (2014) 142 ALD 410
Husband v Repatriation Commission (2000) FCA 356SECONDARY MATERIALS
Statement of Principles concerning Fibromyalgia – Instrument no. 14 of 2014
Statement of Principles concerning Chronic Fatigue – Instrument no. 12 of 2014REASONS FOR DECISION
Deputy President Dr P McDermott RFD
12 July 2018
INTRODUCTION
The applicant, Mr Phillip Dorsett, served in the Australian Army (“the Army”) from 4 February 1975 to 4 July 2006, a period of more than 31 years. Prior to his discharge from the Army the applicant served in the role of Regimental Quartermaster Sergeant, Warrant Officer Class 1. The applicant is now 65 years of age and has not undertaken any remunerative work since the time of his discharge.
The applicant has a number of medical conditions which have been accepted by the respondent as war-caused, including post-traumatic stress disorder, alcohol dependence, and ischaemic heart disease. The applicant currently receives 100% of the general rate of the disability pension from the Department of Veterans’ Affairs (“DVA”).
The applicant now seeks to qualify for receipt of the special rate of the disability pension.
BACKGROUND
On 1 November 2013 the applicant lodged a claim with DVA for the conditions of post-traumatic stress disorder and alcohol dependence. On 10 April 2014 DVA accepted these conditions with effect from 1 August 2013, and the result was that the applicant’s pension was continued at 100% of the general rate.[1]
[1] Exhibit A, T-Documents, T13.
In their decision DVA identified the reason that disability pension at the special rate was not granted as: “[the applicant] retired from the workforce in 2006, has not worked since that time and is not currently seeking further employment.”[2] It was also noted that time out of the workforce would have contributed considerably to the applicant’s inability to work.
[2] Ibid at p. 77.
On 1 July 2014 the applicant requested a review of the decision dated…
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- Case
- [2018] AATA 2241
- Decision Date
CaseChat Overview and Summary
The primary legal issue before the Tribunal was whether the applicant met the criteria for the special rate of pension under section 24 of the Act. Specifically, the Tribunal had to determine if the applicant was "totally and permanently incapacitated" and, crucially, if he was, by reason of his accepted war-caused conditions alone, prevented from continuing to undertake remunerative work. This involved examining whether non-accepted conditions or other factors played a role in his inability to work, thereby potentially failing the "alone" test.
The Tribunal applied the established principle from *Repatriation Commission v Watkins* and other Federal Court decisions, which holds that the "alone" requirement is not satisfied if non-war-caused factors contribute to preventing a veteran from engaging in remunerative work, even if those factors are of secondary importance. The Tribunal found no evidence that the applicant was prevented from continuing remunerative employment by reason of his accepted conditions alone. While the applicant's PTSD and alcohol dependence were accepted, the Tribunal noted that other factors, including his muscle and bone pain (which were not accepted as distinct conditions), his age, lack of recent work experience, and personal preferences, were considered by the respondent to have prevented him from obtaining work. The Tribunal concluded that the applicant did not satisfy the "alone" test under section 24(1)(c) of the Act.
Consequently, the Tribunal affirmed the decision of the respondent, finding that the applicant was not entitled to pension at the special rate. The applicant's disability pension was continued at 100% of the general rate.
Orders
Orders of the court
Full text does not contain this section.
Background
Background to the litigation
Evidence
Evidence Before The Court
Decision
Reasons for decision
Ratio Decidendi
Legal Principle Established
The respondent submits that the applicant also fails to satisfy the criterion outlined in subsection 24(2)(b) of the Act. The respondent contends that the genuine seeking of remunerative work must be proximate to the assessment period. They also argue that the applicant’s incapacity was not the substantial cause of his inability to obtain work. The respondent considers that a variety of other factors prevented the applicant obtaining work, including the existence of his muscle and bone pain, his age, his lack of recent work experience, the death of his friend, the lack of support for his franchise idea, a lack of training and professional experience in his chosen fields, and his preference not to take a job out of Brisbane for family reasons. CONSIDERATIONSpecial rate – “Alone” test It is not in contention, and the Tribunal accepts, that the applicant meets the threshold criteria in order to qualify for the special rate of pension. I have to determine whether section 24(1)(c) of the Act is met. This one criterion in contention is often referred to as the “alone” test and requires that "the veteran is, by reason of incapacity from that war-caused injury or war-caused disease, or both, alone, prevented from continuing to undertake remunerative work that the veteran was undertaking..." In Repatriation Commission v Watkins [2015] FCAFC 10, the Full Court of the Federal Court of Australia referred to the decisions of Repatriation Commission v Richmond [2014] FCAFC 124; (2014) 226 FCR 21, Repatriation Commission v Hendy [2002] FCA 602; (2002) 76 ALD 47 and Repatriation Commission v Butcher [2007] FCAFC 36; (2007) 94 ALD 364 and reaffirmed the settled principle that: “...if non war-caused factors play a part in or contribute to preventing a veteran from engaging in remunerative work, even if those preventative factors are of secondary importance and not of themselves sufficient to prevent remunerative work, the “alone” requirement will not be satisfied.” (at [41]) In this context the reference to “war-caused factors” is taken to be a reference to defence-caused factors. The respondent accepts that the work that the applicant was undertaking was as a soldier, quartermaster and logistics officer. At the time of his voluntary discharge the applicant had a medical assessment and the assessment did not warrant him being discharged medically. The medical assessment enabled him to be transferred to the Army Reserve. The applicant was not employed after his retirement. There is no evidence that the applicant was by reason of an accepted condition prevented from “continuing to undertake remunerative employment” within the meaning of s 24(1)(c) of the Act. In his 2009 pension application, the applicant remarked that he had “retired from military service”; that application does not make reference to any mental health condition. While the applicant has not made a claim for payment of pension at the intermediate rate of pension, in my view he is not entitled to pension at that rate as I am not reasonably satisfied that he meets the requirements of the “alone” test in section 23 of the Act.Ameliorating provisions