J.D. v. HHS - Influenza, small fiber neuropathy (2022)
Case summary [AI summaries can sometimes make mistakes]
J.D., an adult, received an influenza vaccine on October 29, 2013. She alleged that this vaccine caused her to develop small fiber neuropathy (SFN), along with other autoimmune illnesses like Raynaud's phenomenon and unspecified diffuse connective tissue disease.
J.D. presented with a complex medical history, including pre-existing conditions and numerous symptoms that emerged over several years. Her initial symptoms before vaccination included wrist pain and bruising, and post-vaccination, her symptoms progressed to include swelling, joint pain, redness, and burning sensations.
J.D. sought compensation under the National Vaccine Injury Compensation Program, arguing that her SFN was caused by the flu vaccine, presenting expert testimony suggesting a plausible biological mechanism of molecular mimicry and an appropriate temporal relationship. Respondent contested the diagnosis of SFN, arguing that her symptoms were diffuse, often lacked objective findings, and predated the vaccination or were attributable to other causes.
Respondent's expert also questioned the timing and the proposed causation theory. The Special Master reviewed extensive medical records and expert opinions.
Ultimately, the court found that J.D. failed to establish by a preponderance of the evidence that her flu vaccination caused her small fiber neuropathy. The court noted that her symptoms did not follow the typical progression of SFN, that her medical history was complex with many co-morbidities, and that her diagnosis of SFN was not confirmed until four years after vaccination, with significant testing and specialist visits occurring in the interim without such a diagnosis.
The court also found the proposed causation theory, based on molecular mimicry and analogies to Guillain-Barré Syndrome, to be insufficiently supported by evidence specific to SFN and the flu vaccine. Therefore, the petition was denied.
Source PDFs
USCOURTS-cofc-1_14-vv-00742