Author: Jessica R. Allen, M.D. | Physician and C&P Examiner

Updated and Reviewed: July 1, 2026

Adams v. Collins and Obesity in VA Disability Claims

Quick answer: On May 15, 2026, the Federal Circuit dismissed the appeal in Adams v. Collins by agreement of the parties. The dismissal order is nonprecedential, but it left the underlying Veterans Court decision undisturbed — the one holding that, for secondary service connection, whether obesity is itself a "disease" or "injury" is not the controlling question. In plain terms: if a service-connected condition caused your weight gain, and that weight gain caused or worsened a condition like sleep apnea, diabetes, or hypertension, obesity can be the legal bridge linking your disability to your service. What decides these claims is the quality of the medical evidence — and that's exactly what a strong nexus letter provides.

Not sure whether this applies to your claim? Get a free phone consultation to find out »

There has been an important update in Adams v. Collins, a case involving obesity, secondary service connection, and how VA must analyze certain disability claims. On May 15, 2026, the U.S. Court of Appeals for the Federal Circuit dismissed the appeal after the parties agreed to dismissal, and the court issued the mandate the same day. The Federal Circuit order itself is nonprecedential, meaning it did not create a new Federal Circuit merits opinion, but it did end the appeal.

What does this mean in plain English?

In practical terms, the government is no longer pursuing the Federal Circuit appeal challenging the Veterans Court’s decision in Adams v. Collins. That matters because the underlying Veterans Court decision remains undisturbed in the case.

The Veterans Court held that VA’s General Counsel opinion was not persuasive to the extent it categorically treated obesity as unable to qualify as a “disability” when obesity causes functional impairment. At the same time, the Court left undisturbed the general rule that obesity is not ordinarily service connected on a direct basis as a disease or injury incurred in service. Most importantly for secondary-service-connection analysis, the Court held that in the secondary service connection context, whether obesity itself is a “disease” or “injury” is not the controlling question.

Why this matters for veterans

Veterans have increasingly used obesity as an intermediate step between a service-connected condition and another chronic disability. The theory has existed for years under VA legal guidance, but it's often resisted or misunderstood in individual claims. Here's how it typically looks:

• Orthopedic pathway: Service-connected back/knee condition → reduced mobility or inability to exercise → weight gain → obstructive sleep apnea, diabetes, or hypertension.

• Medication pathway: Service-connected mental health or pain condition → medications associated with weight gain → obesity → sleep apnea or metabolic disease.

• Psychiatric pathway: Service-connected PTSD, depression, or anxiety → disrupted sleep, low motivation, emotional eating, inactivity → weight gain → additional chronic disability.

The VA's own General Counsel previously recognized that obesity may serve as an intermediate step between a service-connected disability and a secondary condition under 38 C.F.R. § 3.310(a).

This is where most veterans get stuck — and where we help. Talk to us about building your chain of evidence »

Related Webpage: Nexus Letters: Sleep Apnea Secondary to Obesity

Important: obesity itself is still not automatically compensable

This update does not mean every veteran with obesity now has a compensable claim for obesity itself. Obesity is still generally not treated as a directly compensable disability.

What changed is the reinforcement of how obesity matters — as a medical and legal bridge. If your service-connected back, knee, foot, PTSD, depression, or medication-related limitations caused or aggravated obesity, and that obesity then substantially contributed to sleep apnea, diabetes, hypertension, or another condition, the obesity may be part of the secondary service connection chain under 38 C.F.R. § 3.310. (eCFR)

The Evidence Is Everything — And That's the Good News

Here's the part most veterans miss: this ruling makes the quality of your evidence more important, not less. The Court has emphasized that these theories require more than a passing mention of weight. There must be evidence associating your weight gain with the service-connected condition, such as:

• Mobility limitations from orthopedic conditions

• Reduced activity from chronic pain

• Difficulty exercising because of a mental health condition

• Medication-related weight gain

• Medical literature, lay statements, and clinician opinions tying it together

The medical facts matter. VA research has reported that Iraq and Afghanistan veterans with PTSD and depression were at particular risk for obesity and difficulty losing weight. The CDC recognizes that obesity can be influenced by stress, sleep, health conditions, and medications — including psychiatric medications such as antipsychotics and antidepressants. And the National Heart, Lung, and Blood Institute recognizes obesity as a risk factor for obstructive sleep apnea, because fat deposits in the neck can obstruct the upper airway.

Translation: the science supports these claims. What's usually missing isn't the medicine — it's a document that organizes the evidence and explains the chain. That document is a nexus letter.

Why a Strong Nexus Opinion Is the Deciding Piece

A persuasive nexus opinion doesn't just say "the veteran gained weight because of service-connected conditions." It walks through the full chain with medical reasoning and answers the questions VA raters actually weigh:

• Did the service-connected condition cause or aggravate the weight gain or obesity?

• Was the obesity a substantial factor in causing or worsening the claimed secondary disability?

• Would the claimed disability have been less likely — or less severe — but for the obesity caused by the service-connected condition?

When those questions are answered clearly, in the VA's own "at least as likely as not" language, a rater has what they need to grant the claim.

Need a Nexus Letter for an Obesity-as-an-Intermediate-Step Claim?

At Brightview Psychiatry Solutions, we have extensive experience preparing medical nexus letters for exactly these claims — cases involving service-connected PTSD, depression, anxiety, chronic pain, orthopedic limitations, medication-related weight gain, reduced activity, and sleep disruption that contribute to obesity and later conditions like sleep apnea, hypertension, or diabetes.

Dr. Jessica Allen, M.D. is a psychiatrist and former C&P examiner. She knows what a rater looks for because she used to be on the other side of the file. Every letter is written to organize your evidence, explain the pathophysiology, address the obesity intermediate-step framework, and apply the correct legal standard.

Here's what happens on your free phone consultation:

1. We review your service-connected conditions, weight history, and current diagnoses.
2. We tell you honestly whether the obesity intermediate-step theory fits your case.
3. If it does, we explain how a nexus letter would connect the evidence — and what it costs.

No pressure, no obligation, and no cost for the consultation. Every case is different, and no medical opinion can guarantee a VA outcome — but a well-supported nexus letter can make sure the medical side of your claim is as strong as the evidence allows.

Get your case reviewed for free You served. Let's make sure the VA sees the full picture. Schedule your free phone consultation »

Frequently Asked Questions

Does Adams v. Collins mean obesity is now compensable?

No. Obesity is still generally not a directly compensable disability. The significance is that the Veterans Court decision — left undisturbed after the appeal was dismissed — reinforces that obesity can serve as an intermediate step linking a service-connected condition to a secondary disability like sleep apnea.

Can I get sleep apnea service-connected because of weight gain?

Potentially, yes. If a service-connected condition caused or aggravated your weight gain, and that obesity substantially contributed to your sleep apnea, you may have a valid secondary claim under 38 C.F.R. § 3.310. These claims usually require a nexus letter that explains the full chain.

What evidence do I need for an obesity intermediate-step claim?

Evidence linking your weight gain to the service-connected condition: mobility or exercise limitations, chronic pain, mental health effects on activity and eating, medication history, medical records, weight history, lay statements, and a clinician's nexus opinion applying the "at least as likely as not" standard.

The VA denied my sleep apnea claim because of my weight. Is that the end?

Not necessarily. Denials that blame obesity often overlook why the weight gain happened. If your obesity resulted from a service-connected condition or its treatment, a well-developed nexus opinion may address the exact gap the VA cited.

Do you guarantee my claim will be approved?

No — and be cautious of anyone who does. Every case turns on its own evidence, and the VA makes the final decision. What we can do is make the medical side of your claim as clear and well-supported as the facts allow.

How do I get started?

Schedule a free phone consultation. We'll review your case, tell you honestly whether the theory fits, and explain how a nexus letter could help.

Ready when you are. Book your free consultation »

This article is for educational purposes only and is not legal or medical advice, and it does not guarantee any claim outcome. For legal strategy, consult an accredited Veterans Service Officer, VA-accredited Claims Agent, or VA-accredited attorney. For the medical side of a claim, a well-supported nexus opinion may help clarify whether the evidence supports an "at least as likely as not" relationship. To read the decision directly, see Adams v. Collins, No. 23-5064.