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

On January 7, 2021, Stephen Cote filed a petition alleging that an influenza vaccination administered on October 11, 2019 caused a left shoulder injury related to vaccine administration. The records placed onset within a day or two of vaccination.

By November 13, 2019, Mr. Cote reported persistent left shoulder pain, difficulty sleeping on the shoulder, and trouble with activity.

He attended a short course of physical therapy in December 2019, reporting mild constant pain, and later described continued pain during an April 2020 telehealth visit. The medical record then contained a long gap in shoulder-specific treatment, with later visits either silent for left shoulder complaints or focused on other issues.

In 2024, he returned with continued shoulder symptoms and went back to therapy, but the Chief Special Master treated the prolonged gap as important when valuing damages. Respondent conceded entitlement, and Chief Special Master Brian H.

Corcoran found Mr. Cote entitled to compensation on November 28, 2023.

Damages were disputed. Petitioner sought a higher award based on ongoing pain, reduced exercise, biking limitations, and daily activities affected by the shoulder.

Respondent argued that the injury was mild and sparsely treated. On September 2, 2025, the Chief Special Master awarded $40,000.00 for past pain and suffering only.

He found that the injury involved full awareness of pain but was mild, conservatively treated, and not well documented for much of the claimed duration. Mr.

Cote was represented by Leah V. Durant.