Mary Miceli v. HHS - Influenza, left shoulder injury related to vaccine administration (SIRVA) (2025)

Mary Miceli filed a petition alleging that an influenza vaccine she received on October 28, 2016, caused a left shoulder injury related to vaccine administration (SIRVA). The court determined that her claim did not meet the criteria for a Table SIRVA injury because her pain and reduced range of motion did not manifest within the required 48-hour timeframe.

The decision noted that her shoulder pain and limitations began gradually and became significant enough to report nearly six months after vaccination, in March 2017. Furthermore, an MRI revealed extensive rotator cuff tears and osteoarthritis, which the court found were not consistent with an inflammatory reaction from the vaccination.

Petitioner did not present evidence to support an off-Table claim. Consequently, the court found that Mary Miceli failed to establish by a preponderance of the evidence that her vaccination caused the alleged injury and denied her claim for compensation.