Doni Corcoran v. HHS - Tdap, left shoulder injury related to vaccine administration (SIRVA) (2025)

Filed 2021-01-08Decided 2025-10-15Vaccine Tdap
compensated$15,000

Case summary [AI summaries can sometimes make mistakes]

On January 8, 2021, Doni Corcoran filed a petition alleging that a Tdap vaccination on May 18, 2019 caused a left shoulder injury related to vaccine administration. Respondent opposed entitlement and moved to dismiss.

The dispute centered on whether Ms. Corcoran actually had left-shoulder pain within 48 hours and whether the injury persisted long enough to satisfy the Vaccine Act's severity requirement.

The entitlement decision describes a thin and conflicting record. Ms.

Corcoran delayed reporting shoulder symptoms, some records were vague, and respondent argued that her continued tennis activity undermined the claim. Chief Special Master Brian H.

Corcoran nevertheless credited her hearing testimony and the surrounding medical record enough to find that the Tdap vaccine was given in the left arm, that pain began within the Table window, and that the residual effects persisted for more than six months. He also found no prior shoulder history or alternative diagnosis that defeated the Table SIRVA claim, though he warned that the sparse and mild record would matter for damages.

Entitlement was granted on September 23, 2025. On October 15, 2025, respondent filed a proffer of damages with Ms.

Corcoran's agreement, while reserving the right to seek review of the entitlement ruling. Chief Special Master Corcoran awarded $15,000.00 for pain and suffering, paid as a lump sum through counsel's IOLTA account.

Theory of causation

Tdap vaccine, May 18, 2019, alleged left SIRVA. COMPENSATED. Respondent contested onset and severity, emphasizing delayed reporting, vague records, continued tennis, and lack of documentation, but Chief Special Master Corcoran credited hearing testimony and record context, found the vaccine was in the left arm, onset occurred within 48 hours, severity exceeded six months, and no alternative condition defeated Table SIRVA. Entitlement September 23, 2025. Award October 15, 2025: $15,000 pain and suffering, lump sum. Respondent reserved review rights on entitlement.

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