Angela Roach v. HHS - Influenza, alleged Guillain-Barre syndrome (2025)
Case summary [AI summaries can sometimes make mistakes]
On November 7, 2017, Angela Roach filed a petition alleging that an influenza vaccination administered on December 6, 2016 caused Guillain-Barre syndrome. She was 39 years old at vaccination.
After Ms. Roach died in 2021, Austin Roach-Yohey continued the case as representative of her estate.
Her death was listed as cardiopulmonary arrest due to fulminant hepatic failure due to alcoholic cirrhosis, and the decision did not treat the death as vaccine-caused. The record was medically complex.
Before and after vaccination, Ms. Roach had liver disease, alcohol-related neuropathy, electrolyte abnormalities, weakness, ataxia, and other neurologic complaints.
Treating clinicians considered GBS or a Miller Fisher variant at points, and she received treatment and rehabilitation. Petitioner argued three theories: Table GBS, off-Table GBS or Miller Fisher syndrome caused by the flu vaccine, and significant aggravation of a pre-existing condition.
Dr. Lawrence Steinman supported petitioner, with later reliance also on Dr.
Robert Fujinami. Respondent opposed the claim with Dr.
Jeffrey Cohen, who emphasized alcoholic neuropathy, hypokalemia, and diagnostic features making GBS less likely. Special Master Christian J.
Moran denied entitlement on October 17, 2025. He found that hypokalemia was an exclusionary criterion for regulatory GBS, defeating the Table claim.
He also found that petitioner had not preponderantly shown Ms. Roach actually had GBS rather than alcoholic neuropathy and related illness.
The significant-aggravation theory failed because petitioner and Dr. Steinman framed the vaccine as triggering a separate autoimmune disease rather than showing that the vaccine worsened alcoholic neuropathy.
No compensation was awarded.
Theory of causation
Influenza vaccine, December 6, 2016, age 39, alleged Table GBS, off-Table GBS/Miller Fisher variant, or significant aggravation of preexisting neuropathy. DENIED. Petitioner experts included Dr. Lawrence Steinman and Dr. Robert Fujinami; respondent relied heavily on Dr. Jeffrey Cohen. Special Master Moran found hypokalemia was an exclusionary criterion for Table GBS, that the record did not preponderantly establish GBS over alcoholic neuropathy/liver-related illness, and that the significant-aggravation theory failed because petitioner framed vaccine-induced GBS as a separate disease rather than a vaccine worsening of alcoholic neuropathy. Ms. Roach died June 23, 2021 at age 46 from fulminant hepatic failure due to alcoholic cirrhosis, not a vaccine-caused death. Decision October 17, 2025; no compensation.
Source PDFs
USCOURTS-cofc-1_17-vv-01744