Patrick Hock v. HHS - Influenza, polyarthritis/rheumatoid arthritis (2020)

Patrick Hock, a 52-year-old male, received a seasonal influenza vaccine on October 20, 2015. Four days later, he presented with severe joint pain and was diagnosed with probable cellulitis and polyarthritis.

His symptoms were initially thought to be a reaction to the vaccine, possibly serum sickness. Over the following months, his condition evolved, and he was diagnosed with seropositive rheumatoid arthritis (RA), a chronic autoimmune disease affecting the joints.

Mr. Hock argued that the flu vaccine triggered his RA, presenting a theory based on molecular mimicry and immune system activation.

He offered expert testimony from Dr. Paul Utz, who detailed a multi-stage immune response theory.

The respondent, the Secretary of Health and Human Services, presented expert testimony from Dr. Chester Oddis and Dr.

Noel Rose. Dr.

Oddis opined that Mr. Hock likely had preclinical RA before the vaccination and that his symptoms were not consistent with full-blown RA.

Dr. Rose, an immunologist, agreed that while molecular mimicry is a valid scientific concept, there was no reliable evidence to support the claim that the flu vaccine could cause or trigger RA.

The court considered the medical records, expert testimonies, and scientific literature. Ultimately, the Chief Special Master denied entitlement, finding that Mr.

Hock's causation theory lacked sufficient medical and scientific reliability to establish that the flu vaccine could cause RA or did so in his case. The court concluded that Mr.

Hock's initial symptoms were more consistent with a transient, vaccine-induced reactive arthritis that resolved, and his subsequent RA was more attributable to his personal history, including family history and smoking, and pre-existing biomarkers, rather than the flu vaccine. The court noted that the one-day onset was too fast for the proposed molecular mimicry mechanism and that the evidence did not support the vaccine initiating a chronic RA process.

Therefore, Mr. Hock did not meet his burden of proof.