Arthur French v. HHS - Influenza, left shoulder post injection edema and rotator cuff and biceps tendinitis without tear (2026)
Case summary [AI summaries can sometimes make mistakes]
On July 15, 2020, Arthur French filed a petition alleging that an influenza vaccination administered in his left arm on October 26, 2019 caused a shoulder injury. He was 80 years old at vaccination and had undergone a left rotator-cuff repair in 2009, but he maintained that he was pain-free before the flu shot.
The Table SIRVA claim had already been dismissed because of evidence of a preexisting shoulder condition. The remaining question was whether the vaccine caused-in-fact, or significantly aggravated, left shoulder post-injection edema with rotator cuff and biceps tendinitis.
Mr. French reported pain about twenty-four to forty-eight hours after vaccination, including muscular pain and pain radiating down the biceps.
The medical record described mild pain, reduced range of motion, and edema, and a treating physician diagnosed post-injection edema and rotator cuff/biceps tendinitis. Respondent argued that the symptoms were more likely recurrence of his prior shoulder pathology and also questioned the six-month severity requirement.
Petitioner's orthopedic expert, Dr. Uma Srikumaran, attributed the condition to vaccine-triggered inflammation; respondent's expert, Dr.
Paul Cagle, favored non-vaccine shoulder disease. Chief Special Master Corcoran found Dr.
Srikumaran's opinion and the treating diagnosis more persuasive, credited the temporal relationship and Mr. French's explanation that COVID-19 disrupted formal therapy, and held that he continued a home exercise program.
On February 26, 2026, entitlement was granted on an off-Table causation-in-fact theory, with damages left for later proceedings.
Theory of causation
Adult petitioner, age 80; influenza vaccine October 26, 2019; left shoulder post-injection edema with rotator cuff/biceps tendinitis. ENTITLEMENT GRANTED, damages pending. Table SIRVA dismissed due to prior shoulder history; off-Table causation accepted. Petitioner expert Dr. Uma Srikumaran; respondent expert Dr. Paul Cagle. SM Corcoran credited post-injection edema/tendinitis diagnosis, 24-48 hour onset, and COVID-related treatment interruption/severity explanation. Petition filed July 15, 2020; entitlement February 26, 2026.
Source PDFs
USCOURTS-cofc-1_20-vv-00862