Trystan Sanchez v. HHS - DTaP, Leigh syndrome / SDHA-related mitochondrial disease with neurodegeneration (2025)

Trystan Sanchez, an infant, through his parents Germain and Jennifer Sanchez, filed a petition for compensation under the National Childhood Vaccine Injury Act of 1986 on October 17, 2011. The petition alleged that Trystan's six-month vaccinations on February 5, 2009, including the DTaP vaccine, caused or significantly aggravated his Leigh's syndrome, a severe neurological disorder diagnosed in late 2014.

The Sanchezes argued that the vaccinations either caused the genetic condition to be expressed or worsened its course. The respondent, the Secretary of Health and Human Services, contested entitlement.

Special Master Christian J. Moran initially denied compensation in a decision dated October 9, 2018.

The Special Master found that while the Sanchezes presented a plausible medical theory that vaccines could cause the manifestation of Leigh's syndrome, the evidence did not demonstrate that this occurred in Trystan's case. The Special Master credited contemporaneous medical records over the family's testimony regarding the timeline of Trystan's decline, finding that Trystan's loss of skills began no earlier than May 2009, approximately three months after the vaccinations, which was too long a period to establish vaccine causation.

The court of Federal Claims sustained this decision. However, the Federal Circuit vacated this decision and remanded the case, finding that the Special Master had not fully considered the petitioners' challenge-rechallenge theory and had made contradictory findings regarding Trystan's arm contortions, which were central to the causation analysis.

The Federal Circuit directed the Special Master to clarify the timeline and causation issues. On remand, the Special Master issued a second entitlement decision on August 26, 2020, again denying compensation.

He found that while the first Althen factor (plausible medical theory) was met, the second (logical sequence of cause and effect) and third (proximate temporal relationship) factors were not. The Special Master concluded that Trystan's symptoms, including arm contortions on February 16, 2009, were consistent with a common cold and not indicative of a neurological injury, and that the onset of Trystan's neurological problems occurred too late to be linked to the vaccinations.

The court of Federal Claims again sustained the Special Master's decision. Petitioners appealed again, and the Federal Circuit reversed the court of Federal Claims' decision, remanding the case to the Special Master for further consideration of entitlement, specifically regarding the timing of Trystan's arm contortions and the challenge-rechallenge theory.

The Federal Circuit also noted that the Special Master might need to address whether Trystan's genetic mutations would have led to the same outcome regardless of the vaccinations. Following the second remand, the Special Master issued a third decision on August 26, 2020, again denying entitlement.

The Special Master found that petitioners had not met their burden for the second and third Althen factors, concluding that the sequence of events was not logical and the temporal relationship was not proximate. The court of Federal Claims sustained this decision.

Subsequently, the Federal Circuit reversed the court of Federal Claims' decision, remanding the case to the Special Master for further proceedings, specifically noting that the Special Master's findings regarding Trystan's arm contortions were contradictory and that the challenge-rechallenge theory had not been fully addressed. The Federal Circuit also suggested the Special Master might need to consider the role of Trystan's genetic mutations.

The Special Master issued a decision on August 26, 2020, again denying compensation. Petitioners sought review of this decision, and the court of Federal Claims sustained the Special Master's denial.

However, the Federal Circuit reversed this decision, remanding the case for further consideration of the causation issue, particularly concerning Trystan's arm contortions and the challenge-rechallenge theory. The Special Master issued a subsequent decision on August 26, 2020, again denying entitlement.

In a later opinion on March 22, 2021, the court of Federal Claims sustained the Special Master's August 26, 2020 decision, denying petitioners' motion for review. However, this decision was later reversed by the Federal Circuit on August 11, 2022.

The case was remanded again. Most recently, on April 16, 2024, Chief Judge Elaine D.

Kaplan denied Petitioners' Petition for a Writ of Mandamus, which sought to have the Court decide the Secretary's motion to reopen entitlement, but ordered the Special Master to unstrike Petitioners' motion to reopen and reinstate it on the docket, while denying the motion itself. Petitioners' subsequent motion for a protective order regarding Ms.

Sanchez's testimony was denied on February 18, 2025, by Chief Judge Kaplan, who found no basis for the court to intervene in interlocutory matters before the Special Master. To date, no compensation award has been made in this case.

The later supplemental materials do not add a damages award. They show continued remand proceedings, including 2025 findings of fact and conclusions of law after years of review, mandamus, and protective-order litigation.

The staged public record still does not show an injury-compensation award.