Laura C. Salzer v. HHS - Influenza, right shoulder injury related to vaccine administration (SIRVA) (2025)
Case summary [AI summaries can sometimes make mistakes]
On November 7, 2019, Laura C. Salzer filed a petition alleging that an influenza vaccine administered on October 26, 2016 caused a right shoulder injury related to vaccine administration.
The vaccination record listed the left deltoid, although a later addendum stated that an employee recalled the injection as right deltoid. The contemporaneous medical record did not support a Table SIRVA presentation.
The first documented right-shoulder complaint appeared on February 23, 2017, almost four months after vaccination. Later physical therapy records gave onset histories that predated or did not clearly match the flu shot, and the first clear report tying pain to the vaccination appeared much later.
Ms. Salzer and her husband submitted declarations describing earlier symptoms, but the special master found them inconsistent with the medical records.
Chief Special Master Brian H. Corcoran denied entitlement on November 7, 2025.
He found that Ms. Salzer had not shown onset within forty-eight hours, had evidence of preexisting or alternative shoulder problems, had symptoms not limited to the vaccinated shoulder/site, and had not supplied a persuasive medical theory satisfying Althen prong one.
No compensation was awarded.
Theory of causation
Influenza vaccine October 26, 2016 causing alleged right SIRVA; adult exact age not stated. DENIED. Vaccination record listed left deltoid, later addendum recalled right deltoid. First documented right shoulder complaint February 23, 2017, nearly four months later; later histories inconsistent/preexisting; declarations found not enough. Dr. Robertson-Shepherd letter did not provide a reliable medical theory. CSM Corcoran denied November 7, 2025 for failure to prove Table onset/localization and Althen prong one. Petition filed November 7, 2019.
Source PDFs
USCOURTS-cofc-1_19-vv-01650