4th Circuit Opinion and VA Malpractice Under FTCA and 38 U.S.C. § 1151
On December 19, 2012, the United States Court of Appeals for the Fourth Circuit issued a published opinion, Butler v. United States, No. 11-2408, distinguishing the evidence neccessary to establish a dependency and indemnity (DIC) claim before the Department of Veterans Affairs (VA) pursuant to 38 U.S.C. § 1151, versus a wrongful death and loss of consortium claim under the Federal Tort Claims...