Abigail Stratton v. HHS - HPV, postural orthostatic tachycardia syndrome (POTS) (2026)

Filed 2020-11-02Decided 2026-01-05Vaccine HPV
dismissed

Case summary [AI summaries can sometimes make mistakes]

On November 2, 2020, Abigail Stratton filed a petition alleging that a Gardasil human papillomavirus vaccine administered on November 6, 2017 caused postural orthostatic tachycardia syndrome. POTS is not listed as an HPV vaccine Table injury, so the claim depended on proof of causation-in-fact.

Ms. Stratton later withdrew the petition so that she could pursue claims against the Gardasil manufacturer, and the Office of Special Masters concluded proceedings in July 2021.

The later public litigation concerned attorneys' fees and costs, not vaccine-injury compensation. Chief Special Master Corcoran initially awarded fees with reductions, but the Federal Circuit remanded for a fuller reasonable-basis analysis.

On remand, the Chief Special Master denied attorneys' fees and costs. He found that the medical records showed POTS-like symptoms before the November 2017 vaccination and that later post-vaccination symptoms were nonspecific or too remote to support the claim.

The Court of Federal Claims affirmed on January 5, 2026, holding that the pre-vaccination symptom record supported the no-reasonable-basis finding. No injury compensation was awarded.

Theory of causation

Adult petitioner; Gardasil/HPV vaccine November 6, 2017; alleged POTS. DISMISSED/withdrawn with no injury compensation; later fees denied and denial affirmed. Medical records showed POTS-like symptoms before vaccination and no adequate temporal relationship; Court did not need to decide general Gardasil-POTS causation. Petition filed November 2, 2020; withdrawal/order concluding proceedings July 2021; fee-review opinion January 5, 2026.

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