Nona Bobb v. HHS - Influenza, left shoulder injury related to vaccine administration (SIRVA) (2025)

On January 7, 2021, Nona Bobb filed a petition alleging that an influenza vaccination on February 6, 2020 caused a left shoulder injury related to vaccine administration, either as a Table SIRVA or a caused-in-fact injury. Respondent opposed compensation, arguing that Ms.

Bobb had not shown pain onset within 48 hours or residual effects lasting more than six months. Chief Special Master Brian H.

Corcoran found that the early record did support a vaccine-time shoulder reaction. Ms.

Bobb first sought treatment on March 17, 2020, reporting left shoulder pain coinciding with the February flu shot and difficulty lifting and moving her arm. Her primary-care provider assessed osteoarthritis and performed arthrocentesis with a corticosteroid injection.

In April 2020 she reported only minimal relief, received a referral to orthopedics, and a shoulder MRI was ordered. The May 22, 2020 MRI showed a small partial supraspinatus tear, mild supraspinatus and infraspinatus tendinopathy, AC joint arthritis, and a small subacromial spur.

After discussing those results on June 22, 2020, Ms. Bobb said she did not want intervention at that time.

The problem was duration. The decision found the contemporaneous records supported vaccine-related symptoms at most through June 2020, about four and a half months after vaccination.

Later left wrist and hand pain in 2021, and later left shoulder complaints in September 2021 and June 2022, were too remote and not sufficiently linked to the vaccination. Declarations from Ms.

Bobb, her daughter, and her granddaughter did not overcome the absence of reliable medical documentation beyond the six-month mark. On September 29, 2025, the case was dismissed for insufficient proof of the Vaccine Act severity requirement.

No compensation was awarded.