Cynthia Price Taylor v. HHS - Influenza, Guillain-Barré syndrome (GBS) (2021)

Cynthia Price Taylor filed a petition for compensation under the National Vaccine Injury Compensation Program, alleging she suffered Guillain-Barré syndrome (GBS) after receiving the influenza vaccine on October 25, 2015. Respondent conceded entitlement, acknowledging that her injury met the Table definition for GBS following the seasonal flu vaccine.

The parties were unable to resolve damages, leading to a hearing on disputed components. The court awarded Ms.

Taylor $166,281.56, comprising $160,000.00 for past pain and suffering and $6,281.56 for past out-of-pocket expenses. Compensation for lost wages was denied.

Ms. Taylor, born March 3, 1951, was 66 years old at the time of vaccination.

She experienced initial symptoms within three days of her first complaint, leading to hospitalization and a diagnosis of probable GBS. She received IVIG and underwent inpatient rehabilitation, showing significant improvement and resolving her incontinency.

Upon discharge, she used a walker and continued pain management. Medical records indicated substantial improvement by March 2016, with normal strength and resolved pain, and by June 2016, she reported being 90 percent improved with a normal neurological examination.

While she later reported some symptoms in 2019, her neurologist attributed them to restless leg syndrome. The court found her GBS symptoms, while significant during hospitalization and rehabilitation, did not rise to the level of severity and duration seen in cases with higher pain and suffering awards, particularly given her good recovery within a year.

Her claim for lost wages was denied due to insufficient evidence of ongoing symptoms significantly impacting her ability to work from her return to work in April 2016 until her retirement in November 2017. The award for expenses included personal training sessions in 2018, deemed helpful for her balance issues and foot pain.