Valarie Williams v. HHS - Influenza, Guillain-Barré syndrome (GBS) (2021)

Valarie Williams filed a petition for compensation under the National Vaccine Injury Compensation Program on January 19, 2021, alleging that she received an influenza vaccine on September 11, 2016, and subsequently developed Guillain-Barré syndrome (GBS). The case was assigned to the Special Processing Unit.

Petitioner initially alleged a "Flu/GBS (Table Claim)". Following procedural steps and extensions, a show cause order was issued on July 1, 2020, directing Petitioner to demonstrate why the case should not be dismissed for insufficient proof.

Petitioner responded on August 14, 2020, stating there were no additional medical records and requesting a ruling based on the existing records. The Special Master noted that the onset of Petitioner's GBS appeared to be outside the timeframe required for a Table claim and potentially even for a non-Table claim.

Petitioner, a 54-year-old adult, received the flu vaccine on September 11, 2016. There were no medical records documenting any reaction to the vaccination until late December 2016.

On December 25, 2016, over 100 days after her vaccination, Petitioner reported symptoms including dizziness, lack of balance, general weakness, and numbness in her legs with tingling that began two days earlier. She was treated and released the same day.

On December 28, 2016, she was treated for weakness and paresthesia that reportedly started three days prior, with a clinical impression of moderate GBS with acute lower extremity weakness. She was admitted to the hospital that day for ascending numbness and tingling after a mild febrile upper respiratory infection the previous week.

She reported numbness in her toes starting December 21, 2016, which moved up her legs, followed by leg and arm weakness. Nerve conduction studies and EMG on January 3, 2017, were suggestive of GBS or acute inflammatory demyelinating polyneuropathy.

A lumbar puncture was negative for GBS, but an EEG confirmed the diagnoses. After a course of intravenous immunoglobulin, Petitioner was admitted for inpatient rehabilitation on January 4, 2017.

Her rehabilitation evaluation on January 23, 2017, noted she had been visiting her boyfriend for Christmas and "ran in a race in which her legs started to lose function," leading to her hospitalization and diagnosis of GBS. Later medical records, created significantly after her hospitalization, associated her GBS with the flu vaccination.

However, these records provided little context regarding the onset of her injury and the relationship between the vaccination and symptoms, and it was unclear if the link was self-reported. Petitioner also submitted a letter from her boyfriend, Stephen E.

Nelson, stating that the week after her flu shot, she experienced weakness, followed by sleeplessness and aching in her feet and legs, and that her legs gave out around Thanksgiving 2016. The Special Master gave greater weight to the contemporaneous medical records from December 2016, which established the onset of symptoms well outside the Table's 3-42 day timeframe for GBS following an influenza vaccine.

The Special Master found that the earliest onset of symptoms was December 21, 2016, which was over 100 days post-vaccination. This late onset precluded a Table claim.

The Special Master also found that the onset date was too late for a non-Table claim, as an onset of more than ten weeks post-vaccination had never been deemed preponderantly possible for vaccine-induced GBS. Petitioner failed to establish that her GBS onset occurred within the required timeframe for a Table claim, and the late onset also precluded a non-Table claim.

Therefore, Valarie Williams' petition was dismissed by Chief Special Master Brian H. Corcoran on March 3, 2021.

Petitioner's counsel was Leah VaSahnja Durant, and Respondent's counsel was Adriana Ruth Teitel.