Potterat and Repatriation Commission (Veterans' entitlements) [2018] AATA 3262 (5 September 2018)
Division:VETERANS' APPEALS DIVISION
File Number(s): 2017/0771
Re:Guy Potterat
APPLICANT
AndRepatriation Commission
RESPONDENT
DECISION
Tribunal:Senior Member D. J. Morris
Date:5 September 2018
Place:Melbourne
The Tribunal sets aside the decision under review and substitutes a decision that Mr Potterat is entitled to the payment of pension at the special rate with a date of effect of 9 August 2016.
..[SGD]......................................................................
Senior Member D. J. Morris
Catchwords
VETERANS’ ENTITLEMENTS – special rate pension – disabling condition – whether by reason of incapacity resulting from war-caused disabilities – whether veteran incapable of undertaking remunerative work for more than 8 hours per week – whether non-war caused preventative factors – ‘alone test’ – Tribunal satisfied that criteria are met - decision set aside and new decision substituted
Legislation
Safety, Rehabilitation and Compensation Act 1988 (Cth)
Veterans’ Entitlement Act 1986 (Cth), ss 19, 22, 23, 24, 25, 120, 177
Cases
Fox v Repatriation Commission [1997] FCA 176
Repatriation Commission v Smith [1987] FCA 327REASONS FOR DECISION
Senior Member D. J. Morris
5 September 2018
Background
Mr Guy Potterat, the Applicant in this matter, seeks to review the decision of the delegate of the Repatriation Commission (the Respondent) of 3 February 2016, which refused to increase his disability pension beyond 100 per cent of the general rate under section 22 of the Veterans’ Entitlement Act 1986 (the Act). That decision was affirmed by the Veterans’ Review Board (the Board) on 13 September 2016. Mr Potterat contends that he satisfies all the criteria set out in section 24 of the Act and as a consequence his pension should be increased to the special rate.
On 17 December 2012 Mr Potterat made a claim for post-traumatic stress disorder (PTSD), adjustment disorder and depressed mood. On 6 March 2013 a delegate of the Respondent decided that the conditions of adjustment disorder and depressed mood were not related to service but accepted Mr Potterat’s application for increased disability pension. The pension was increased to 50 per cent of the general rate, with effect from 17 December 2012. On 20 November 2013 Mr Potterat made an application for review of that decision to the Board. On 24 September 2015 the Board amended the diagnoses and accepted alcohol use disorder in remission and PTSD as related to service. The Board referred the matter to the Repatriation Commission for assessment of the disability pension (T17, p 99). On 3 February 2016 a delegate of the Respondent increased the rate of Mr Potterat’s disability pension to 100 per cent of the general rate, with effect from 26 May 2013 (T17, p 99). As mentioned above, on 15 February 2016 Mr Potterat applied for a review by the Board of this decision, and the Board affirmed it. That is the matter before the Tribunal.
The hearing was held from 6 to 7 June 2018. Mr Potterat was represented by Ms Fiona Spencer, of…
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- Case
- [2018] AATA 3262
- Decision Date
CaseChat Overview and Summary
The legal issues before the AAT included whether Mr Potterat was totally and permanently incapacitated by his war-caused conditions, and crucially, whether these conditions *alone* prevented him from undertaking remunerative work for periods aggregating more than eight hours per week. This required the Tribunal to assess the extent to which his post-traumatic stress disorder (PTSD) and any physical ailments contributed to his work incapacity, and to apply the "alone test" as stipulated by the Act. The Tribunal also had to consider the permanence of his condition and the appropriate date from which any increased pension entitlement should commence.
The Tribunal's reasoning focused on the medical evidence presented, particularly the reports from psychiatrists. It noted Dr Ewer's 2014 diagnosis of chronic PTSD, his assessment that Mr Potterat was unfit to work more than eight hours per week, and his recommendation for a conservative approach to rating the condition as "temporary" pending treatment. The Tribunal found that this assessment was confirmed by later opinions, such as that of Dr Strauss in May 2017, and was satisfied that Mr Potterat's condition was permanent. The Tribunal accepted submissions that Mr Potterat's career was cut short by his PTSD and that there was no evidence he ceased work for reasons other than this war-caused condition.
Consequently, the Tribunal set aside the previous decision and substituted a new decision finding Mr Potterat entitled to payment of pension at the special rate. This entitlement was backdated to 9 August 2016, being six months prior to the date Mr Potterat lodged his application with the Tribunal.
Orders
Orders of the court
Full text does not contain this section.
Background
Background to the litigation
Full text does not contain this section.
Evidence
Evidence Before The Court
Decision
Reasons for decision
Ratio Decidendi
Legal Principle Established
Dr Grant said that he did not think that Mr Potterat could do work which required a lot of new learning. Mr Potterat had significant issues but not, in his view, no work capacity. He said that Mr Potterat was different and delicate compared to a person without his symptomology, and agreed that there was a risk of unpredictability in the course of the condition. Dr Grant said it was his view that Mr Potterat could not work an eight-hour day but could work in 3 or 4 hour lumps.Consideration To satisfy section 24(1)(b) of the Act, Mr Potterat must be totally and permanently incapacitated by his war-caused conditions, which alone prevent him from continuing to undertake remunerative work for periods aggregating more than eight hours per week. Ms Spencer submitted that Mr Potterat’s career in the Army was cut short by his PTSD condition. She said that he was up for promotion and there is no evidence he ceased for any reason other than the PTSD. Ms Spencer pointed to Mr Boatwright’s evidence about Mr Potterat’s physical fitness and the high scores in the annual basic fitness tests that he undertook. Ms Spencer said that the only evidence among all the medical reports that Mr Potterat’s physical conditions were affecting him was in Dr Horsley’s report. She submitted that Dr Horsley had, in her report summary, misunderstood the physical tasks Mr Potterat had been undertaking as a military instructor. Ms Spencer drew the Tribunal’s attention to the medical report of Dr Marty Ewer, psychiatrist, dated 2 December 2014 (T11, p 42). Dr Ewer concluded:In my clinical opinion, based upon a reasonable degree of medical probability Mr Potterat is suffering from a chronic post-traumatic stress disorder. He was exposed to a number of traumatic events during his time in Kosovo and Bosnia during his time in the army and these distressed him greatly. He has re-experienced the traumas in the form of flashbacks and intrusive recollections. There is evidence of avoidant symptoms and increased physiological arousal in the form of sleep disturbance and an exaggerated startle reaction.(Emphasis in original.) At T11, p 51, Dr Ewer, after quantifying Mr Potterat’s disability by referring to chapter four of the Guide to the Assessment of Rates of Veteran’s Pensions (GARP), edition 5, concluded that the Applicant was unfit to work 8 hours per week. This equates to an impairment rating of 8. Later in the report (T11, p 52), Dr Ewer wrote:Given that Mr Potterat has yet to receive the benefit of psychiatric treatment I would take a conservative approach and rate his current mental state as “temporary”. Should there be no change with eight to ten months of psychiatric treatment I would consider his psychiatric state to be “permanent.” It would seem to the Tribunal that Dr Ewer’s diagnosis at the end of 2014 and his assessment of work capacity has unfortunately been confirmed by Dr Strauss’s clinical opinion of May 2017, some 29 months later. The Tribunal is satisfied, on the medical evidence, that the condition is permanent.