Aretta Diane James v. HHS - Influenza, Guillain-Barré syndrome (GBS) (2021)

Aretta Diane James filed a petition alleging Guillain-Barré syndrome (GBS) caused by an influenza vaccine received on October 19, 2016. She claimed the GBS onset occurred less than a month after vaccination.

The respondent argued that the onset was approximately four months post-vaccination, which is outside the Table timeframe for GBS and too long for a non-Table causation claim. The court reviewed medical records and found that symptoms arguably attributable to GBS did not appear until mid-February 2017, approximately four months after vaccination.

Prior symptoms reported by Ms. James were consistent with pre-existing conditions like fibromyalgia, diabetic neuropathy, and chronic back pain.

The court determined that the four-month onset period did not meet the Table requirements nor the proximate temporal relationship needed for causation-in-fact. As Petitioner failed to provide preponderant evidence establishing a medically appropriate onset timeframe, the case was dismissed for failure to provide sufficient supporting evidence.