Sherrill Cote v. HHS - Influenza, rheumatoid arthritis (2026)

Sherrill Cote filed a petition alleging that hepatitis B and/or influenza vaccinations received on May 10, 2016, caused her to develop rheumatoid arthritis (RA). The alleged injury, RA, is not listed on the Vaccine Injury Table, so Ms.

Cote had to prove causation-in-fact under the Althen test. She presented expert opinions from Dr.

M. Eric Gershwin and Dr.

Omid Akbari, who theorized that the vaccines could have triggered RA through various immune mechanisms, including inflammasome activation and molecular mimicry, and that her symptoms began approximately four days after vaccination. Respondent presented expert opinions from Dr.

Christopher A. Mecoli and Dr.

John T. Bates, who disputed the proposed causal mechanisms and noted a lack of strong epidemiological evidence linking the vaccines to RA.

The court found that Ms. Cote failed to establish a reputable medical theory under Althen prong one, as the proposed mechanisms were not persuasively supported by the evidence and existing literature did not demonstrate a causal link between the vaccines and RA.

Furthermore, the court noted that Ms. Cote's medical history, including a concurrent respiratory infection and a history of smoking, provided alternative explanations for the onset of her RA.

Ultimately, the court concluded that Ms. Cote did not meet her burden of proof and denied her claim for compensation.