For example, if your hip pain stems from ankylosis, you could be eligible for a 60%, a 70%, or even a 90% schedular disability rating. You can file a secondary claim to get more disability benefits for a new disability thats linked to a service-connected disability you already have. If a veteran has a hip condition which resulted from a service-connected knee condition, they may be eligible for secondary service connection. This may help speed up the claim decision process so you can get your benefits sooner.Find out how to file a pre-discharge claim, If you have less than 90 days left on active duty, you cant file your claim through the BDD program. How to Establish Direct Service Connection for Knee Pain, Limitation of Flexion of the KneeDiagnostic Code 5260, Limitation of Extension of the KneeDiagnostic Code 5261, Instability of the KneeDiagnostic Code 5257, Ankylosis of the KneeDiagnostic Code 5256, Total Knee ReplacementsDiagnostic Code 5055, Establishing Secondary Service Connection for Hip Pain, Compensation and Pension Exams for Hip Pain Secondary to Knee Pain, How an Accredited Representative Can Help You with Your Hip Pain Secondary to Knee Pain, VA Secondary Conditions Related to Knee Pain, VA Disability Ratings for Hip Pain and Hip Conditions, Outside of the hip, upper thigh, or outer buttock (usually caused by problems with muscles, ligaments, tendons, and other soft tissues surrounding the hip joint), An in-service event, injury, or illness; and, A medical nexus linking the current, diagnosed knee condition to the in-service incurrence, A current diagnosis of hip pain or a hip condition that is secondary to knee pain or a knee condition, Medical evidence showing the relationship between the knee condition and hip pain. When asked by the VA to submit current medical evidence for your claim, have your physician submit a report showing the severity of your non-service-connected disability. OTE5NDllNzI4YTJhMWUwMDRiOGQ4ZjI4YWY0YzBhMzYxNWE2Njk4MTQ1MjQ5 Then send a one-sentence letter to the VA stating that you disagree with the decision. If you have hip pain due to osteoarthritis, you could see a disability rating of between 10% and 20%. Due to the nature of back injuries, it is common for other parts of the body or bodily functions to be affected by secondary conditions to back pain. MzE1OTVlM2EyYzRlNTk3OTE3ODdjYTQzYmYzMDRmYjQ3YTQ3Nzk1NmM4MWM1 We also offer a free ebook The Road to VA Compensation Benefits, to help break down the claims process from start to finish. YmU5NThmYjA2YzNhOWYzYmRkNzQwIiwic2lnbmF0dXJlIjoiNzk5ZDNjYmM1 Chicago, IL: 332 S. Michigan Avenue, Floors 8 and 9, Chicago, IL 60604 Develop arthritis thats caused by a service-connected knee injury you got while on active duty, Develop heart disease thats caused by the high blood pressure you were diagnosed with while on active duty and that wed previously concluded was connected to your service. Weve supported more than 20,000 veterans to win their claims and increase their ratings. This data may be used to help optimize our websites and make them easier for you to navigate. As you compensate for your knee pain, your opposite hip might be doing extra work. When expanded it provides a list of search options that will switch the search inputs to match the current selection. If this is the case, veterans must inform VA of the hip replacement surgery as soon as possible. Tune in to learn how VA rates Veterans for various hip pain, hip replacements, hip arthritis, and other disabilities plus common secondary conditions to be aware of, potentially qualifying you for a higher combined VA rating. When you visit web sites, they may store or retrieve data in your web browser. Find out when you can first file a claim for service-connected benefitsand what to do if you want to request more benefits or have new evidence to support a claim we denied in the past. Nevertheless, it is very possible that a veterans hip pain may be caused or aggravated by their DDD. The only exception to this rule is when the right hip gets worse solely by itself, which is called a natural progression.. Do You Have Long-Term Disability Insurance Coverage? This information is not a substitute for legal advice. Types of VA disability claims and when to file | Veterans Affairs Now what? How to File a VA Claim for Chronic Pain - HEALTH IS GOLD Youll need to submit up-to-date medical evidence that shows your disability has gotten worse. Federal law under 38 CFR 3.310 governs these claims, and once granted, the secondary condition is considered a part of the original condition. While appellate litigation proceeded, the Contact Us If you have a complete hip replacement, it will be rated under diagnostic code 5054. While we still have our home base in Florida, As noted, the VA considers you totally disabled for one year after your hip replacement. Back conditions are one of the most common medical complaints that the Department of Veterans Affairs sees. First, his service medical records will be reviewed, and if they are negative for complaints for any arthritis of the back, his claim will be denied. The logic here is that the veteran is experiencing a new health problem since leaving the military that was not present at all during the time he or she served. Because hip pain can be caused by various bodily injuries or issues, the VA rating for hip pain will depend on its cause and pain levels. Service connection can thus be granted for the arthritis of the right hip. Unlike total knee replacements,partial knee replacements do not have their own diagnostic code. You had an illness or injury before you joined the militaryand serving made it worse (called a preservice disability claim), You have a disability related to your active-duty service that didnt appear until after you ended your service (called a postservice disability claim), Chronic (long-lasting) back pain resulting in a current diagnosed back disability, Breathing problems resulting from a current lung condition or lung disease, Loss of range of motion (problems moving your body), Cancers or other conditions caused by contact with toxic chemicals or other dangers. In the beginning stages of urinary frequency, you may not notice anything out of the ordinary. MTgwY2NiZjdmZTAyYmY1ZjA3NjBjNjNlOGIzOTJmZGY0MjNkZTUzZDcyMWRm MTE1NmMxOTdhZDk0ODY1ZGY4MzE5NjlmMzM0NDNlYzMxMjUxZGEyODUwZDY2 Knee pain is a particularly common problem among veterans. Seattle, WA: 506 2nd Ave,Suite 1400,Seattle, WA 98104. A new claim differs from a reopened claim in that a decision on the claim is totally independent of any evidence submitted in connection with an earlier claim. If pain, weakness or limitation on ROM forces the veteran to use crutches or other mobility aids, a 90% rating is assigned. M2YyNGU5MTkwOGI5NWIyOTE4MDM5ZmU1OGUwMDA3NGIwZmMxYzYwZjYwOTNm Accredited representatives can be extremely beneficial in guiding you through the VA appeals process and helping to secure benefits for hip pain secondary to knee pain. As a result, treating hip pain is essential for managing knee pain. Contacting us does not create an attorney-client relationship. Youve got a service-connected disability rated at 90 percent. You must file a claim with the VA to receive compensation for this secondary condition. Top 10 Easiest Claims for VA Disability This Year - VA Claims Insider Camp Lejeune Lawsuit. Urinary frequency or incontinence are typically symptomatic of another underlying condition, however, it is important to know that you can also receive compensation for urinary dysfunction separately. Review VA disability benefits eligibility criteria to find out if you can get disability compensation for an illness or injury that was caused byor got worse because ofyour active military service. It is because the iliotibial band attaches to the hip at a point known as the greater trochanter, and when it becomes inflamed, it can cause pain in this area. A hip fracture is a break in the upper part of the thighbone (femur) that affects the hip joint. Furthermore, as to case summaries, reports of past results, individual lawyer biographies, news posts and other information pertaining to past and present cases, these descriptions are meant only to provide information to the public about the activities and experience of our law firm. If you continue to use this site we will assume that you are happy with it. It is known as secondary hip pain. If you have a direct service connection for your back condition and have developed any of these conditions or symptoms of these conditions, you may be entitled to VA benefits due to secondary disability and are entitled to a VA disability rating for the same. Amy Mallette is a Claims Advocate for Hill and Ponton. Cookies help us deliver the best experience on our website. Many veterans suffer from injuries incurred during an in-service event while serving their country. Without these cookies, services you have asked for cannot be provided. Generated by Wordfence at Sat, 4 Mar 2023 4:42:13 GMT.Your computer's time: document.write(new Date().toUTCString());. These are claims for disabilities that developed as a result of or were worsened by another service-connected condition. NTNkYzQzOTUwYjFlOGE1NjE0OGZiOWY0MTc4NTAyZWFiN2Q1NzE4OGRkM2U4 YTUyOGM4NTg3ZmFlYzY3NjFkNTExNjI3M2U4ZGY4OGFiMzNmZDRmNjgxYzhh By using our website, you agree to the use of certain cookies. If the entire knee joint has beenreplaced by a prosthesis, then the condition is rated 100 percent for the first year following surgery. Without these cookies, services you have asked for cannot be provided. M2FjOGVhNTY1ZTYzMjNhZWViNmUzZDgzOTNiYmMyODMyYjUzYzA4NTE1Zjk5 They may also be used to keep track of what [products, video, links, etc.] An official website of the United States government. You can file an increased claim to request: Our decision on your new claim will be based only on new evidence (like a doctors report or medical test results) that you give us to support your claim. The https:// ensures that you're connecting to the official website and that any information you provide is encrypted and sent securely. Thus, knee problems are often thought of as isolated issues, but they can lead to pain in other body parts, such as knee and hip pain. One of the most commonly affected nerves is the sciatic nerve, which causes pain down the back of the thigh into the calf and foot. There are several key steps that disabled veterans should follow when seeking to receive benefits for chronic pain. According toVAs Annual Benefits Report for Fiscal Year 2020, the limitation of flexion of the knee was the second most prevalent service-connected disability among new compensation recipients (meaning those who became service-connected during the 2020 fiscal year.). By taking these steps, veterans can have a high chance of winning their claim so they receive the benefits and care they need to manage their knee pain. The first step is to apply for a secondary disability rating for chronic pain. A specially equipped vehicle if your service-connected disability prevents you from driving. Hip fractures can be caused by falls or other trauma. Myelopathy is a back condition that is caused from a previous trauma or injury. When you have a service-connected disability, the VA is responsible for providing you with necessary medical care and benefits. His first novel, A Thirst for War, was a semi-finalist in the 2009 William Faulkner Competition. Pro Tip: Many service connected physical conditions can cause or aggravate mental health conditions, and vice versa. Click the link below to learn more. As mentioned earlier, ankylosis-caused hip pain starts at 60% and can be rated up to 90% disability rating for hip pain. For example, if your hip pain is caused by arthritis, the VA will assign a rating of 10% or 20% based on 38 CFR 4.71a. Also known as Individual Unemployability, TDIU benefits are available to veterans who are unable to work due to their service-connected disabilities. Estimate your 2023 VA Rating & Compensation for FREE! We have updated our Privacy Policy. This information is made available for educational purposes only and to provide general information and a general understanding of the law. The specific location of an individuals hip pain can provide important information about the underlying cause. Learn more in our Cookie Policy. Typically, VA rates this condition based on the range of motion that exists as the veteran moves their knee in that direction. NGVhOTk0YzIwOTMwMzkxYzY1ZDk1MWRjYjk3N2ZiNDgzOTQxZDIxNjZiYzU1 MDUwNmZkODllMDI2NTlhNDVjOWM3NTY0NTU2NGQ4YmM4MjQ1ODhlYTE4MjE2 Finally, we invite you to contact us and we welcome your calls, letters and electronic mail. Ankylosis VA ratings are classified under Diagnostic Code 5250. The hip joint is stabilized by several muscles, tendons, and ligaments, which can adversely affect knee problems. As with limitation of flexion of the knee, there are specific range of motion measurements that correspond with each disability evaluation. Mjg4NGVhYzE3MjVmZDE0OTRhOGJhZTA2YjNhN2RiY2EzYzk4NjVmZGFiYWNl PDF UNITED STATES COURT OF APPEALS FOR VETERANS CLAIMS No. 18-0495 This information is not a substitute for legal advice. You're not alone. After reviewing the hospital report to verify that there was, in fact, a stroke, payment of benefits at the one hundred percent rate would be granted for the stroke (a neurological condition) for a period of six months during the course of the condition. This button displays the currently selected search type. The .gov means its official. This condition is detected by MRI and usually requires surgery. After the one-year period, the hip condition will be assigned a permanent rating based on the level of severity as outlined above. Yjc5M2U3MTA0N2I0NDhkZGUxYWU0NGUwY2MwMDFlZmZiMjQwMTE4ZGIxYzEy [Updated 2020 Mar 25]. For example, you might file a Supplemental Claim if you were treated for pain in your elbow while on active duty, but you were denied disability benefits because your VA health exam didnt find a problem. For example, a veteran claims service connection for arthritis of the back as secondary to his service connected left ankle condition. What is the VA Disability Rating for Hip Pain, Submitting VA Claim Hip Secondary to Knee. Learn what youve been missingso you can FINALLY get the disability rating and compensation you deserve! Trochanteric bursitis:Trochanteric bursitis is a type of bursitis that causes pain on the outside of the hip. Likewise, VA disability hip pain secondary to knee pain might allow a service-connected knee injury to form the basis of a secondary service connection to the hip replacement. These cookies are necessary for the website to function and cannot be switched off in our systems. The sequel, In the Hands of the Wolf, was a semi-finalist in the 2011 William Faulkner Competition, and won Third Prize at the 2012 Florida Writers Association convention. NDQwOTU5ZDdkYjQzN2E1Y2M2YWY2MDllYzU2YTcxZGFkMTUyMGQ1M2ZmYWU4 These cookies dont collect information that identifies you. In this case, the veteran should file a claim for VA benefits. Philadelphia, PA: 1 International Plaza, Suite 550, Philadelphia, PA, 19113 One of the most common injuries is knee pain. These cookies are necessary for the website to function and cannot be switched off in our systems. However, many people dont realize that knee pain can cause hip pain. eyJtZXNzYWdlIjoiMTZhOGRlZjlhYjUzOWM1YWFjZDZiNTI1YmZlYjRkYzc2 We refer to the first claim you file for a disability as your original claim. However, if the veteran experiences pain or ROM limitations one year after surgery, they can receive a higher VA rating. When you visit web sites, they may store or retrieve data in your web browser. He then deducts the baseline level (as well as any increase due to natural progression) from the current level to arrive at the percentage evaluation of the disability. In order to establish secondary service connection, you will need to submit: VA disability ratings for hip pain depend on the underlying cause and the severity of the pain itself. Va Claims For Hip Pain Secondary To Ddd - pnpfitness.com but they can lead to pain in other body parts, You Deserve It: The Definitive Guide to Getting the Veteran Benefits Youve Earned, 9 Secrets Strategies for Winning Your VA Disability Claim. Its FREE to get started, so click Go Elite Now below to complete our 3-step intake process. For some conditions, we automatically assume (or presume) that your service caused your condition. VA Disability Benefits for Hip Pain Secondary to Knee Pain Veterans Law VA Disability Benefits for Hip Pain Secondary to Knee Pain May 11, 2022 Knee pain is very common among veterans, often due to the physicality of military service. If your service-connected disability limits your ability to work or prevents you from working, find out if you can get VR&E benefits and serviceslike help exploring employment options and getting more education or training if required. Cincinnati, OH: 300 E Business Way, Suite 200, Summit Woods Corporate Center, Cincinnati, OH, 45241 Heres the brutal truth about VA disability claims: We use cookies to ensure that we give you the best experience on our website. Hill & Ponton P.A. NTM0MjYwYjM1NTQ5NzljMzExNDY0MjVjMWQ0ZTUyNWQ1MzAwZWVhNmE4MzNj Knee pain can also cause hip pain, or other hip conditions. NzJkM2VlMDc2NGFkNzQzMWIzY2ExYTAzYzJhYTg5ZGNkNzU5ZGEzNDNlMjUx ZGJjMDU3MDYyYzJkODQyOWFmYTNjMjhmODNhMjc4ZjNiNjFlNTI4ODRlOTFi Hip pain is a relatively common problem that can be caused by a variety of underlying problems and health conditions. Specifically, a veteran may change the way they are walking, standing, or sitting because of the pain stemming from their DDD. However, this may place undue pressure on your hips, leading to osteoarthritis. VA Disability Ratings for Hip Pain and Hip Conditions - YouTube A hip replacement surgery qualifies you for a minimum 30 percent VA disability rating for hip pain. Cincinnati, OH: 300 E Business Way, Suite 200, Summit Woods Corporate Center, Cincinnati, OH, 45241 If you find yourself using the restroom more than usual or experiencing incontinence, it is a good idea to keep a diary of how often you go, any accidents, whether you need to wear absorbent material, and/or how often you must change due to accidents. MmNmMzdhNDA3NDI2YTYwOGE5MTk4ZTk5OGM2OGUxNTg5ODRmMDRkMjQ0NGU4 The life of a soldier inherently invites physical exertion and wear-and-tear injuries. Eligibility For VA Disability Benefits | Veterans Affairs Filing a claim for secondary service connection involves the same process as filing any claim for service connection. All information these cookies collect is aggregated and therefore anonymous. The Department of Veterans Affairs (VA) uses a disability rating system to evaluate the severity of a veterans service-connected disabilities and assign a corresponding benefit amount. In some cases, the knee pain can be so severe that it leads to hip pain. This can be submitted via mail to the Evidence Intake Center or electronically throughVAs website. Given the physicality required for many military occupations, this is not surprising. To establish direct service connection, veterans must provide the following: Veterans can submit a claim for VA disability benefits onVA Form 21-526EZ. The claims process can be complex, but working with an experienced Veteran Coach at VA Claims Insider can help to ensure that your claim is properly submitted and that you receive the benefits you deserve. There are many different causes of hip pain, but some are more common than others. At VA Claims Insider, we help you understand and take control of the claims process, so you can get the rating and compensation youre owed by law. For more on TDIU, go here. This results in pressure on the nerve roots themselves. 100% could be warranted if theres a hip replacement or amputation. If you experience osteoarthritis in your hips because of the instability of the knee, you may receive secondary service connection at 20 percent for your hip osteoarthritis. You can file a claim up to 180 days before leaving the service: If you have 180-90 days left on active duty, you may be able to file a pre-discharge claim through the Benefits Delivery at Discharge (BDD) program. Even if the veteran is fully recovered and pain free, a 30% rating is still assigned. YjllYzU5YWUxNGZjZDA4MjVlN2Y5ZmY1NmVmZTI5ZmE2ODdkY2UwNjcxZTE0 Brooklyn, NY: 300 Cadman Plaza West, One Pierrepont Plaza, 12th Floor, Brooklyn, NY, 11201 Tucson, AZ: One South Church Avenue, 12th Floor, Tucson, AZ, 85701 you viewed to avoid repetition. Do You Have Long-Term Disability Insurance Coverage? YmRmMTFhZTM0NGZhNTAzNjMyNTM0ZDljOTg1YzNkZDYyOGUyMmI1YzY0Mjc3 San Jose, CA: 2880 Zanker Road, Ste. All hip replacements are rated at least 30% disability irrespective of the effect on the veteran. In claims for secondary service connection, providing a positive nexus opinion (i.e., link) is especially important. The PACT Act is a new law that expands access to VA health care and benefits for Veterans exposed to burn pits and other toxic substances. Hip Pain and Hip Replacement Surgery VA Ratings for Disability In this post, we reveal and explain the complete VA disability conditions list by VA Disability Hip Pain Secondary to Knee Pain, Creating Service Connection for Knee Pain. Common side effects of myelopathy include radiculopathy (sharp-shooting pain or radiation), loss of urinary or bowel control, and increased reflexes in the arms or lower extremities (depending on which form of myelopathy you have). VA Disability Rating for Hip Pain - Gerling Law By using this information, you understand that there is no attorney-client relationship created by you reading or using the information contained on this website or in this newsletter, article, or blog. To get the highest evaluation, the knee must be so unstable that it gives out or dislocates on a regular basis. Patients also may experience numbness, weakness, or loss of reflexes in the legs. ZDUwMzY5YTM1Y2VkNDMzMWJkZmFkYTA3Y2FjMWE5ZWM2NGU1MDQxODY3Mjlm Contact us at (844) 567-1185. [2] Myelopathy. Myelopathy | Johns Hopkins Medicine,www.hopkinsmedicine.org/health/conditions-and-diseases/myelopathy. Most often, problems within the hip joint itself tend to result in pain on the inside of the hip or groin. ZWE4MzQ3Y2NkMDc0ODhhMjQ2M2M0OWY0Mzk3MzM3MTJjNGVlYzBhYjcxMTAx It is because the patellar tendon attaches to the hip and the knee, and when it is inflamed, it can pull on the hip joint and cause pain. Columbus, OH: 100 E. Campus View Boulevard, Suite #250, Columbus, OH, 43235 R. at 3158. You only need to meet the service requirements for the presumption. Federal government websites often end in .gov or .mil. Some of the most common knee problems can include sprained ligaments, cartilage tears, tendonitis, and arthritis. On a VA medical examination the veteran will state that with any prolonged standing or walking he begins to have pain over the lumbar region. You can update your choices at any time in your settings. 2023 VA Disability Conditions List by Body System (The Ultimate Guide). They may be used by those companies to build a profile of your interests and show you relevant advertisements on other websites. Pittsburgh, PA: 201 Penn Center Boulevard, Suite 400, Pittsburgh, PA, 15235 If you have signs of an illness that started within a year after you were discharged from active service, find out if you can get disability benefits. YjExM2FhYjM5NjZlNjU4YTA3OGY0NTYzN2M3NDM1NTIwNDgwNzdiNGMwMTU5 These cookies allow the website to remember choices you make to give you better functionality and preferences such as text size, fonts and other customizable website elements. Typically, the greater limitation of extension (or the harder it is to straighten the knee), the higher the disability rating. The attorneys at Hill & Ponton are here to support you in your claim for disability benefits for hip pain. Many veterans suffer from injuries incurred during an in-service event while serving their country. To be able to file for hip secondary to your knee, you will need a diagnosis for your hip, your knee condition must be currently service-connected and a nexus letter linking your hip diagnosis to your service-connected knee condition. NjVlZDc0N2UxOGFmNWJiMmFhYjcxYzk3NWZmNWIzYTE2MTg3Y2Q1YzAwNDA5 Radiculopathy is classified as a pain syndrome and can be caused by several lowerback conditions such as lumbar disc herniation, degenerative disc disease, and spinal stenosis. The veteran is asked to submit medical evidence, and fails to do so. MTUzYmUzZTVkMjU3ZWU2ZDUwNWQ2YzQ2MDI0YTYwOWI4NjkwNWNmYTA1ODY4 As reported in the VA's most recent Annual Benefits Report, musculoskeletal disabilities are the most commonly claimed condition in the VA disability benefits system, making up 36.9 percent of all disability claims. If a veteran files a claim for service connection, or secondary service connection, VA may request acompensation and pension exam (C&P). You could also receive service connection for hip . Brian Reese here, Air Force service-disabled Veteran and Founder @ VA Claims Insider. For example, if you have a service-connected knee injury, you may develop hip pain. It can affect the cervical spine (upper back/neck area), thoracic spine (mid-back), and lumbar spine (low back). Survivor and dependent compensation (DIC), Upload evidence to support your disability claim, File additional forms for your disability claim, Change your VA direct deposit information, Get help from an accredited representative, A chronic (long-lasting) illness that appears within 1 year after discharge, An illness caused by contact with contaminants (toxic chemicals) or other hazardous materials, An illness caused by your time spent as a prisoner of war (POW), Find out how to apply for a discharge upgrade, Learn about the VA Character of Discharge review process, Disabilities that appear within 1 year after discharge, Accessing VR&E through the Integrated Disability Evaluation System (IDES). These cookies allow the website to remember choices you make to give you better functionality and personal features. For example, if your hip pain stems from ankylosis, you could be eligible for a 60%, a 70%, or even a 90% schedular disability rating. A secondary disability claim is a condition that was caused or made worse by an already existing service-connected condition. Next, he will state one of the following: the NSC disability was caused by the SC disability; or there was a natural progression of the NSC condition. YjY2YTJhMDU1YjNjZTQ0NWQyNmQxYzJhNDMwNjgwYzcxYTIxN2I4Mjg3ZDA1 Hip pain is very common among the general population and can cause a variety of problems and complications. You got sick or injured while serving in the militaryand can link this condition to your illness or injury (called an inservice disability claim). MzE0NzkwMzk1ZWQyYjRkMDY3YWNmM2NiYzZhNDZkOWJkNjQ2ZGI3MzAyMjVl Knee pain is a common problem, particularly among veterans. If you have a presumptive condition, you dont need to prove that your service caused the condition. NDY1ODc5MmJmMzlmOGY2ODNjMDVjZjdjZjkwNjAzY2ExYWI3YjY5OWNiZGU3 In 2015, over 1.3 million veterans were receiving disability compensation for a mental related condition such as PTSD, general anxiety disorder, major depressive disorder, etc. These benefits can include monthly disability payments, free medical care, and access to specialized treatment programs. MzA0MDgyZTZiNTcxZjRiYTA2N2JlMmQwMzkwMjU2NTMzZTRmM2EwN2MxZWRj All information these cookies collect is aggregated and therefore anonymous. Fractures:Hip fractures are most common in older adults. In some cases, however, a secondary condition may develop due to your primary disability. -----END REPORT-----. She is a proud University of Central Florida alumnus, graduating in 2019 with a bachelors degree in Legal Studies.