Teresa Lee v. HHS - Influenza, shoulder injury related to vaccine administration (SIRVA) (2025)

Filed 2021-01-08Decided 2025-11-25Vaccine Influenza
entitlement_granted_pending_damages

Case summary [AI summaries can sometimes make mistakes]

On January 8, 2021, Teresa Lee filed a petition, later amended on July 10, 2023, alleging that an influenza vaccination administered in her right arm on September 8, 2020 caused a shoulder injury related to vaccine administration. The medical record described tingling and pain shortly after vaccination.

The pain improved the day after the shot but worsened the following day, with significant pain and weakness. Ms.

Lee later reported right shoulder pain rated seven out of ten, worse with overhead activity and reaching behind her back. She received oral medication, physical therapy, orthopedic care, and steroid injections; the first steroid injection helped about 75 percent for one week before symptoms returned.

Records also documented painful range of motion, positive impingement signs, and recommendations for MRI and continued therapy. Respondent argued that the statutory six-month severity requirement was not met, pointing to limited treatment and some records showing full range of motion.

Chief Special Master Corcoran disagreed. He found that the record showed residual effects lasting more than six months, including continued pain at the December 2020 orthopedic follow-up and no affirmative evidence of early resolution.

He also found the remaining Table SIRVA criteria satisfied. On November 25, 2025, Ms.

Lee was found entitled to compensation. Damages remain pending.

Theory of causation

Adult petitioner; influenza vaccine September 8, 2020; right Table SIRVA. ENTITLEMENT GRANTED, damages pending. Tingling/pain shortly after shot, significant pain/weakness, PT, medication, steroid injections, painful ROM/impingement signs, MRI recommended. Respondent disputed six-month severity; SM Corcoran found residual effects and all Table/statutory requirements satisfied. Petition filed January 8, 2021; amended July 10, 2023; entitlement November 25, 2025.

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