Courtney Lane v. HHS - Influenza, right shoulder injury related to vaccine administration (SIRVA) (2025)

On January 6, 2021, Courtney Lane filed a petition alleging that an influenza vaccination administered in her right deltoid on October 25, 2019 caused a Table shoulder injury related to vaccine administration. She was thirty-nine years old at vaccination.

The case turned on onset. Ms.

Lane did not return for in-person medical care until January 16, 2020, but the first treatment record described right arm pain after the flu injection and pain at the right-deltoid injection site from the October flu vaccine. A later orthopedic record stated that pain began a couple of hours after the October 2019 flu shot, which she reported had been administered high in the shoulder.

Examination showed tenderness, pain with abduction and forward flexion, positive impingement signs, and reduced supraspinatus strength. MRI showed subscapularis and supraspinatus tendinosis, impingement, and mild subacromial bursitis.

On May 15, 2020, she underwent arthroscopic shoulder surgery with distal clavicle resection, debridement, and subacromial decompression. She returned in autumn 2020 with ongoing stiffness and was assessed with SIRVA and frozen shoulder.

Respondent contested only whether pain began within the forty-eight-hour Table window, pointing to the delay in formal treatment and to telephone records that did not fully match Ms. Lane's recollection of several early calls.

Special Master Daniel T. Horner found the medical histories consistently placed onset within forty-eight hours and that the telephone note saying the flu-injection arm still hurt supported, rather than defeated, her account.

He also found no prior right-shoulder dysfunction, pain and reduced range of motion limited to the vaccinated shoulder, and no other condition explaining the symptoms. On November 17, 2025, he found Ms.

Lane entitled to compensation; damages remain pending.