Judith Wilson v. HHS - Influenza, rheumatoid arthritis (2024)
Case summary [AI summaries can sometimes make mistakes]
Judith Wilson filed a petition alleging that she developed rheumatoid arthritis (RA) as a result of an influenza vaccination received on October 13, 2015. She was 61 years old at the time of vaccination.
Her medical history included breast cancer, obesity, asthma, scoliosis, obstructive sleep apnea, irritable bowel syndrome, and arthritis of the left wrist. She also had a history of smoking.
Following the vaccination, she reported right shoulder pain, which later spread to her hands and jaw. She was diagnosed with seropositive RA in January 2016.
Petitioner's expert, Dr. Kristin Gowin, proposed a theory of molecular mimicry, suggesting the flu vaccine could cause RA by activating T-lymphocytes.
Respondent's expert, Dr. Mehrdad Matloubian, disagreed, citing the lack of evidence linking the flu virus or vaccine to RA, the long preclinical phase of RA, and Petitioner's history of smoking as a known risk factor.
The court considered the Althen prongs for off-Table claims. Regarding the first prong (medical theory), the court found Dr.
Gowin's molecular mimicry theory unpersuasive, noting that the flu virus itself has not been shown to cause RA and that larger studies did not support a link between the flu vaccine and RA. For the second prong (logical sequence of cause and effect), the court found that Petitioner's treating physicians did not attribute her RA to the vaccine, and that her history of smoking was a more likely contributing factor.
For the third prong (temporal relationship), the court noted that while symptoms appeared weeks after vaccination, this alone was insufficient without a sound causal theory. Ultimately, the court concluded that Petitioner failed to prove by a preponderance of the evidence that the flu vaccine caused her RA and dismissed her petition.
Source PDFs
USCOURTS-cofc-1_17-vv-01264