William Smith v. HHS - Influenza, Guillain-Barre Syndrome (GBS) (2019)

William Smith filed a petition for compensation under the National Vaccine Injury Compensation Program, alleging that a flu vaccine administered on March 14, 2014, caused him to develop Guillain-Barre Syndrome (GBS). Mr.

Smith had a complex medical history, including uncontrolled type 2 diabetes, which caused various symptoms. Two days before his vaccination, he was hospitalized for shortness of breath, heart failure, and renal failure.

He received the flu vaccine during this hospitalization. Shortly after discharge, he was admitted to another hospital for sudden weakness in his legs.

While GBS was considered in the differential diagnosis, treating neurologists and specialists ultimately attributed his symptoms to his pre-existing diabetes and a stroke he experienced during his hospitalization. Nerve conduction studies and cerebrospinal fluid tests did not support a diagnosis of GBS.

The respondent argued that Mr. Smith was neither diagnosed with nor treated for GBS.

After extensive briefing and expert reports, the Special Master ruled that Mr. Smith had not met his burden of proving he suffered from GBS.

The court found that his condition was explained by his pre-existing diabetes and the stroke. Subsequently, Mr.

Smith moved to dismiss his own petition, stating he could not prove entitlement. The court granted his motion and dismissed the petition for insufficient proof.