Marina Angdahl-Wangler v. HHS - Influenza, Guillain-Barré syndrome (2016)

Marina Angdahl-Wangler filed a petition alleging that the influenza vaccine she received on October 28, 2013, caused her Guillain-Barré syndrome (GBS). She claimed the GBS onset nine and one-half weeks after vaccination, but only one week after a diarrheal illness.

The respondent is the Secretary of Health and Human Services. During a status conference, the Special Master noted that the treating doctor attributed the GBS to a diarrheal illness with positive cytomegalovirus titers, and that the court typically requires onset within eight weeks for GBS vaccine claims.

The petitioner subsequently filed a Motion for a Decision Dismissing Petition, stating she would be unable to prove entitlement to compensation. The Special Master granted this motion, dismissing the case.

The decision emphasized that petitioners must prove causation by a preponderance of the evidence, including a medical theory, a logical sequence of cause and effect, and a proximate temporal relationship, and that mere temporal association is insufficient. The medical records did not support the petitioner's allegations, and she had not filed an expert report.