Rodney Koehl v. HHS - Hepatitis B, epidermolysis bullosa acquisita (EBA) (2025)

On February 24, 2020, Rodney Koehl filed a petition for compensation under the National Vaccine Injury Compensation Program, alleging that his hepatitis B (Hep B) vaccinations caused him to develop epidermolysis bullosa acquisita (EBA). Mr.

Koehl received a three-dose series of the Hep B vaccine, with the first dose on December 22, 2016, the second on January 23, 2017, and the third on July 24, 2017. He was 49 years old at the time of his first vaccination.

The parties agreed that Mr. Koehl suffers from EBA, but disputed the onset date and causation.

Respondent argued against compensation, stating the case was not appropriate for compensation under the Act. The court found that Mr.

Koehl failed to provide preponderant evidence that his Hep B vaccinations caused his EBA, thus failing to satisfy the three prongs of the Althen test for off-Table claims. Specifically, the court found that Mr.

Koehl's expert, Dr. Alan N.

Moshell, did not provide a sound and reliable medical theory connecting the Hep B vaccine to EBA, and that the medical literature did not support such a link. Furthermore, no treating physician attributed Mr.

Koehl's EBA to the vaccinations. While the court found a proximate temporal relationship between the last vaccination and the onset of EBA (late August or early September 2017), this alone was insufficient to prove causation.

Consequently, the petition was dismissed. Petitioner was represented by Isaiah Kalinowski of Bosson Legal Group, P.C., and Respondent was represented by Tyler King of the U.S.

Department of Justice. The decision was issued by Special Master Nora Beth Dorsey.