J.H. v. HHS - MMR, vaccine-induced immune dysregulation resulting in erythema multiforme and Type 1 diabetes (2015)

Markus and Candace Heinze, as parents and natural guardians of J.H., a minor, filed a petition on April 21, 2014, seeking compensation under the National Vaccine Injury Compensation Program. They alleged that a measles-mumps-rubella (MMR) vaccine administered to J.H. on April 22, 2011, caused vaccine-induced immune dysregulation resulting in erythema multiforme and Type 1 diabetes.

J.H. was approximately three years old at the time of vaccination. The respondent, the Secretary of Health and Human Services, argued that the medical records did not support a diagnosis of immune dysregulation, that prior case law did not support a link between the MMR vaccine and Type 1 diabetes, and that the alleged rashes did not meet the six-month duration requirement for compensable injuries under the Vaccine Act.

The petitioners did not offer a medical expert opinion to establish causation. The public decision does not describe the specific symptoms or clinical course of the alleged immune dysregulation.

J.H. received the MMR vaccine on April 22, 2011. Eleven days later, on May 3, 2011, she developed a rash and vomiting.

A visit on May 5, 2011, diagnosed a nonspecific rash and lymphadenopathy. By May 24, 2011, her skin was clear.

On September 9, 2011, J.H. was diagnosed with erythema multiforme (or a morbilliform rash), which persisted for four days. On September 16, 2011, J.H. was diagnosed with Type 1 diabetes, with a family history of diabetes noted.

The Special Master, Nora Beth Dorsey, found that the petitioners failed to demonstrate entitlement to compensation. The alleged rashes did not meet the six-month duration requirement for compensable injuries.

The public decision does not describe any specific medical expert opinions presented by either party, nor does it detail the specific mechanism by which the vaccine allegedly caused the injuries. The court found that no medical expert opinion supported causation for Type 1 diabetes, and prior case law did not support a link between the MMR vaccine and Type 1 diabetes.

The petition was dismissed for insufficient proof. The decision was issued on January 27, 2015.

Petitioner counsel was Mark Theodore Sadaka. Respondent counsel was Ryan Daniel Pyles.