Shaunyia Brunson v. HHS - Rotavirus, Sudden Infant Death Syndrome (SIDS) (2020)

On April 14, 2017, Shaunyia Brunson filed a petition on behalf of her infant child, T.A., alleging that routine childhood vaccinations administered on May 28, 2015, caused or significantly contributed to T.A.'s death from Sudden Infant Death Syndrome (SIDS) on June 2, 2015. The vaccines administered were rotavirus, DTaP, HIB, IPV, and pneumococcal 13.

SIDS is not listed on the Vaccine Injury Table, so petitioner had to prove causation-in-fact under the Althen test. Petitioner's expert, Dr.

Douglas C. Miller, a neuropathologist, opined that vaccines could act as an exogenous stressor within the Triple Risk Model of SIDS, particularly in vulnerable infants with a defective serotoninergic network in the medulla oblongata.

He suggested that vaccine-induced cytokines could cross the blood-brain barrier and interact with the central nervous system, leading to death. Dr.

Miller also noted T.A. had a hippocampal abnormality (dysplasia of the dentate gyrus) and a low-grade viral pneumonia, which he believed could contribute to SIDS. However, the Special Master found Dr.

Miller's theory unpersuasive and not sound and reliable, citing previous Federal Circuit decisions like Boatmon and Nunez that rejected similar arguments. The court noted that Dr.

Miller's theory was an extension of the Triple Risk Model not supported by general scientific literature and relied heavily on his own assertions. Furthermore, the court found that T.A.'s autopsy did not reveal the specific medullary defect required by Dr.

Miller's theory; instead, T.A. had a hippocampal abnormality that could be an alternative explanation for SIDS. The court also noted that Dr.

Miller's own report suggested that the viral pneumonia and unsafe sleep conditions (swaddling with blankets) were more likely exogenous stressors in T.A.'s case. The court found that Dr.

Miller's explanation for how vaccines could act as exogenous stressors was based on animal studies that were not applicable or had used non-physiologic doses of cytokines, and that the timing of T.A.'s death, five days after vaccination, was inconsistent with the typical timeframe for vaccine-induced cytokine responses, suggesting the pneumonia was a more likely stressor. Respondent's experts, Dr.

Andrew MacGinnitie and Dr. Sanda Alexandrescu, opined that epidemiological studies show no relation between vaccination and SIDS, and that T.A.'s death was likely due to established SIDS risk factors.

Consequently, the Special Master concluded that the petitioner failed to establish the necessary prongs of the Althen test and denied the petition. The decision was issued by Special Master Daniel T.

Horner on September 28, 2020.