George Taylor v. HHS - Hepatitis A, right shoulder injury related to vaccine administration (SIRVA) (2025)
Case summary [AI summaries can sometimes make mistakes]
On March 23, 2020, George Taylor filed a petition alleging that a hepatitis A vaccination administered on July 2, 2019 caused a right shoulder injury related to vaccine administration. He was 54 years old at vaccination.
The case turned on whether the vaccine had actually been administered in the right arm. The record contained a vaccine document indicating left-deltoid administration, while Mr.
Taylor alleged a right-sided injury. Chief Special Master Brian H.
Corcoran issued a situs ruling finding the record did not support the right-arm administration necessary for a Table SIRVA claim. The court gave Mr.
Taylor time to decide whether he could proceed with an off-Table causation-in-fact claim, which would have required additional proof and likely expert support. After that opportunity, no adequate causation-in-fact theory was developed.
On August 21, 2025, the case was dismissed for insufficient proof. No compensation was awarded.
Mr. Taylor was represented by David J.
Carney.
Theory of causation
Hepatitis A vaccine on July 2, 2019, age 54, alleged right SIRVA. DISMISSED. The record contained a vaccine record showing left-deltoid administration while petitioner alleged right-sided injury. Chief Special Master Corcoran found petitioner had not proven right-arm situs for a Table SIRVA and had not developed a causation-in-fact theory with expert support after being given time to do so. No compensation. Decision August 21, 2025. Attorney: David J. Carney.
Source PDFs
USCOURTS-cofc-1_20-vv-00322