Angela Apuzzo v. HHS - Influenza, chronic inflammatory demyelinating polyneuropathy (CIDP) and Sjögren's syndrome (2025)

Filed 2017-12-08Decided 2025-04-02Vaccine Influenza
denied

Case summary [AI summaries can sometimes make mistakes]

Angela Apuzzo received an influenza vaccine on September 17, 2015. She subsequently developed symptoms of numbness and tingling, initially diagnosed as Guillain-Barré Syndrome (GBS) and peripheral demyelinating neuropathy.

Over time, her diagnosis evolved, with some physicians suspecting CIDP and others Sjögren's syndrome. Petitioner's experts, a neurologist and a rheumatologist, suggested a 'mosaic of autoimmunity' possibly triggered by the vaccine, with the neurologist noting a change in diagnosis to small fiber neuropathy.

Respondent's experts, including neurologists and rheumatologists, disputed the CIDP diagnosis, arguing that the petitioner's symptoms were inconsistent with CIDP and that her condition, likely Sjögren's syndrome, may have predated the vaccination. The Special Master denied compensation, concluding that the preponderance of the evidence indicated Ms.

Apuzzo suffered from Sjögren's syndrome, not CIDP, and that causation by the vaccine was not established. The Court of Federal Claims affirmed this decision, finding that the Special Master appropriately evaluated the competing expert opinions and that the petitioner failed to meet her burden of proof for a vaccine-related injury.

Theory of causation

Influenza vaccine on September 17, 2015, adult exact age not stated, alleged to cause CIDP and/or Sjogren's syndrome/small fiber neuropathy with symptoms about 18 days later. DENIED. Petitioner Angela Apuzzo relied on neurologic and rheumatologic experts and a mosaic-of-autoimmunity theory. Respondent's experts disputed CIDP diagnosis and attributed symptoms to Sjogren's or non-vaccine causes, possibly predating vaccination. Special Master Horner dismissed the petition September 20, 2024; Senior Judge Loren A. Smith denied review April 2, 2025.

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