Michelle Han v. HHS - Hepatitis A, left shoulder injury related to vaccine administration (SIRVA) (2024)

Michelle Han filed a petition for compensation under the National Vaccine Injury Compensation Program, alleging she suffered a left shoulder injury related to vaccine administration (SIRVA) from a Hepatitis A vaccine received on April 22, 2019. The core issue was whether her injury met the Vaccine Act's severity requirement of persisting for more than six months.

Ms. Han reported significant pain and swelling four days after vaccination, and an MRI showed mild rotator cuff tendon inflammation.

She underwent physical therapy for her shoulder and hip, with her last shoulder therapy session on July 3, 2019, at which point she had normal range of motion and strength. Crucially, she did not seek treatment or complain of shoulder pain for over five months after this.

During this period, she completed 30 days of physically rigorous military training without documented shoulder complaints and received treatment for other issues like hip and knee pain. While she reported left deltoid pain in December 2019 and again in February 2020, the court found the evidence did not preponderate in favor of the conclusion that her SIRVA likely continued for more than six months post-vaccination.

The court noted her ability to complete strenuous training and the lack of shoulder complaints during multiple medical visits for other ailments. Consequently, Ms.

Han failed to establish the severity requirement, and her claim was dismissed.