{"package_id":"USCOURTS-cofc-1_03-vv-00654","decision_granule_id":"USCOURTS-cofc-1_03-vv-00654-0","petitioner_identifier":"William Yates Hazlehurst","is_minor":1,"age_at_vaccination":1.0,"age_unit_raw":"years","vaccine_type":"MMR","vaccination_date":null,"condition_raw":"autism","condition_category":"ASD_autism","autism_spectrum_adjacent":1,"outcome":"dismissed","award_amount_usd":null,"decision_date":"2025-07-16","extraction_version":"gemini-v2","extracted_at":"2026-04-30T00:28:30.636574+00:00","number_of_concurrent_vaccines":1,"dose_number":1,"time_to_onset_days":30,"theory_of_causation":"Petitioner Rolf Hazlehurst, on behalf of his son William Yates Hazlehurst, alleged that the MMR vaccine caused William's autism. This case was one of three \"test cases\" for Theory 1 of the Omnibus Autism Proceeding (OAP), which examined whether the MMR vaccine, or MMR combined with thimerosal-containing vaccines (TCVs), could cause autism. The OAP concluded in 2009 and 2010 with denials of entitlement, affirmed by the Federal Circuit, finding the medical theories unsupported. Sixteen years later, Hazlehurst filed a motion under Rule 60(d)(3) alleging fraud on the court by the Department of Justice (DOJ). The core of the alleged fraud was that the government's expert, Dr. Andrew Zimmerman, believed vaccines could cause autism in children with mitochondrial dysfunction, and that the DOJ concealed this opinion while conceding the Hannah Poling case, which involved mitochondrial disease and vaccines. The court found no fraud on the court, holding that Dr. Zimmerman's opinions were not concealed, the Poling case was a Table injury concession distinct from the OAP test cases, and the alleged misconduct did not meet the stringent standard for fraud on the court. The court denied the motion for relief from judgment, and the underlying autism claim remains decided as denied.","is_death":0,"date_of_death":null,"petition_filed_date":"2007-10-15","case_summary":"On July 16, 2025, the Court of Federal Claims reissued an Opinion and Order denying a motion for relief from judgment filed by Rolf Hazlehurst, acting as conservator for his son, William Yates Hazlehurst. The original judgment, entered in 2009 and affirmed in 2010, had denied entitlement for William's alleged autism, which the petitioner claimed was caused by the MMR vaccine. This motion, filed sixteen years after the original judgment, alleged that the United States Department of Justice (DOJ) committed fraud on the court during the Omnibus Autism Proceeding (OAP). The petitioner's core argument was that the government's expert, Dr. Andrew Zimmerman, held a belief that vaccines could cause autism in children with mitochondrial dysfunction, and that the DOJ concealed this opinion while simultaneously conceding a similar case, Hannah Poling. The petitioner contended that the DOJ improperly used Dr. Zimmerman's report and mishandled the Poling concession to mislead the OAP decision-makers.\n\nJudge Edward H. Meyers, writing for the court, detailed the history of the National Childhood Vaccine Injury Act and the OAP, which was established to address thousands of claims alleging that vaccines cause autism. The OAP involved test cases to determine general causation, including three cases for Theory 1, which examined whether the MMR vaccine, or MMR combined with thimerosal-containing vaccines (TCVs), could cause autism. William Hazlehurst's case was one of these Theory 1 test cases. The court noted that the OAP concluded with Special Masters and the Federal Circuit finding the medical theories unsupported and the evidence insufficient to establish causation.\n\nThe court then addressed the petitioner's fraud allegations. Regarding Dr. Zimmerman, the court found that his opinions on William specifically were not concealed. While Dr. Zimmerman had expressed to DOJ attorneys that vaccines could cause autism in a subset of children with mitochondrial dysfunction, this theory was not at issue in the OAP test cases, and the Poling paper detailing this theory was already in the record. The court found that the DOJ's decision not to call Dr. Zimmerman as a witness was a strategic litigation choice, and that leaving his initial report in the record, which stated no scientific basis for a link between MMR and autism, was not a concealment of his later, more nuanced views. The court also noted that Dr. Zimmerman's expert report played a minimal role in the original Cedillo and Hazlehurst decisions.\n\nConcerning the Hannah Poling case, the court determined that it was compensated as a Vaccine Injury Table injury, meaning causation was presumed, not based on an actual causation finding. This was procedurally distinct from the OAP test cases and not inconsistent with their denial. The court found no evidence that the DOJ suppressed Dr. Zimmerman's report in the Poling case or misrepresented the basis of the concession.\n\nThe court applied the stringent standard for \"fraud on the court,\" which requires proof of deliberate, egregious conduct that corrupts the judicial process. It found that the petitioner failed to meet this burden. The court concluded that the alleged actions by the DOJ constituted, at most, ordinary trial tactics or minor evidentiary discrepancies, not a scheme to interfere with the judicial system's impartial adjudication. The court also dismissed the petitioner's constitutional challenge to the Vaccine Act, finding it could not be raised in a Rule 60(d) motion and would fail on its merits regardless, as the Act provides a no-fault compensation system with avenues for appeal and the option to pursue claims in state court.\n\nUltimately, the court denied the motion for relief from judgment, upholding the original denial of entitlement for William Yates Hazlehurst's alleged vaccine injury.","is_minor_inferred":1,"is_pediatric_broad":1,"special_master":"George L. Hastings Jr.","petitioner_identifier_original":null,"caption_petitioner_name":null,"petitioner_attorney_name":"Rolf G.S. Hazlehurst","petitioner_attorney_firm":"Children’s Health Defense","petitioner_attorney_location":"Jackson, TN","adjudicator_name":null,"caption_people_backfilled_at":null,"attorney_canonical_keys":"|rolf-hazlehurst|","firm_canonical_key":"children-s-health-defense","package_title":"HAZLEHURST et al v. SECRETARY OF HEALTH AND HUMAN SERVICES","canonical_url":"https://vicp-registry.org/case/USCOURTS-cofc-1_03-vv-00654","plain_text_url":"https://vicp-registry.org/case/USCOURTS-cofc-1_03-vv-00654.txt","json_url":"https://vicp-registry.org/case/USCOURTS-cofc-1_03-vv-00654.json","source_documents":[{"granule_id":"USCOURTS-cofc-1_03-vv-00654-0","title":"HAZLEHURST et al v. SECRETARY OF HEALTH AND HUMAN SERVICES","docket_text":"JUDGE VACCINE REPORTED OPINION (PUBLIC VERSION) re: 141 Judge Vaccine Reported Opinion denying 118 Motion for Relief from Judgment. Signed by Judge Edward H. Meyers. (dmc) Service on parties made.","date_issued":"2025-07-16","pdf_url":"https://api.govinfo.gov/packages/USCOURTS-cofc-1_03-vv-00654/granules/USCOURTS-cofc-1_03-vv-00654-0/pdf","pdf_bytes":450633,"triage_decision":"keep","triage_reason":"docketText matches keep keyword 'opinion'","download_status":"ok","registry_pdf_url":"https://vicp-registry.org/pdf/USCOURTS-cofc-1_03-vv-00654/USCOURTS-cofc-1_03-vv-00654-0"}]}