Jessica Watts v. HHS - Influenza, Guillain-Barré syndrome (2019)

Jessica Watts filed a petition on October 11, 2017, seeking compensation under the National Vaccine Injury Compensation Program, alleging that an influenza vaccine administered on October 12, 2014, caused her to develop Guillain-Barré syndrome (GBS). Ms.

Watts was 23 years old at the time of vaccination. Her symptoms began around October 23, 2014, approximately ten days after vaccination, with complaints of headache and sore throat, followed by lower extremity numbness and weakness.

She was admitted to Indiana University Health Methodist Hospital, diagnosed with GBS, and treated with intravenous immunoglobulin. She showed improvement and was discharged to an inpatient rehabilitation hospital on October 29, 2014, remaining there until November 12, 2014.

A follow-up visit on December 1, 2014, indicated improved strength, though she noted continued weakness in her hips. Her sensory symptoms had resolved, and her facial strength was improving.

She was instructed to begin outpatient physical and occupational therapy. At this point, approximately forty days after symptom onset, her symptoms had been present for just under six weeks.

By the end of January 2015, she reported to a new physician that she had fully recovered, with the exception of hip weakness, and her neurological exam was normal. Subsequent medical records from May 2015, and a visit for family planning advice, indicated her GBS had resolved, with no complaints of ongoing neurological symptoms.

The medical record was silent regarding GBS or other neurological complaints for over two years until June 2017, when she sought treatment for nausea and vomiting, with a normal neurological exam. She also received treatment in August 2017 for injuries from a motor vehicle accident, with no GBS-like symptoms reported and a normal neurological exam.

The first record referencing her 2014 GBS after January 2015 was from September 28, 2017, when she saw an osteopath, Molly Binkley, D.O. Ms.

Watts, who was consulting with her current counsel about filing the claim, alleged persistent weakness, numbness/tingling, and pain since 2014. Dr.

Binkley's examination revealed some reduced grip strength and finger abduction/adduction, noting "some residual weakness in hands, and this affects [patient’s] ADLs [activities of daily living]." The public decision does not name Petitioner's counsel or Respondent's counsel. Special Master Brian H.

Corcoran presided over the case. Respondent initially disputed proof of vaccination but later conceded it.

The primary dispute centered on whether Ms. Watts suffered residual effects of GBS for more than six months after vaccination, as required by the Vaccine Act.

Special Master Corcoran found that the medical records did not support this requirement. He noted that the period from late January 2015 to September 2017 showed no complaints of GBS-related symptoms, no treatment sought for such symptoms, and no corroborating neurological evaluations.

The September 2017 record, obtained shortly before filing the claim and not in consultation with a neurologist, was considered less probative than the intervening period of no reported symptoms. The Special Master determined that the severity requirement was not met, and therefore, Jessica Watts's claim was dismissed.

No compensation was awarded.