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

On January 11, 2021, Thomas Alley, a 66-year-old retired data-processing worker, filed a petition alleging that an influenza vaccine administered in his left arm on August 11, 2020 caused a left shoulder injury related to vaccine administration. He also received a pneumococcal vaccine in his right arm that day.

Before vaccination, the record showed no history of left-shoulder pain or dysfunction. Mr.

Alley described immediate left-shoulder pain and restricted movement within 24 hours. On September 2, 2020, his primary-care provider recorded pain in the upper left arm since the flu shot, point tenderness at the lateral shoulder, and sharp pain with arm elevation, diagnosing bicipital tendinitis and recommending conservative care.

He later declined an orthopedic referral, contracted COVID-19, and moved to Georgia, creating a long gap in formal treatment. In June 2021, a new provider documented decreased left-shoulder abduction.

Respondent opposed compensation, emphasizing the treatment gap and limited early objective findings. Chief Special Master Brian H.

Corcoran found that Mr. Alley had shown onset within 48 hours, reduced range of motion, and residual effects lasting more than six months.

He granted entitlement and awarded damages in the same October 14, 2025 decision. Because the injury was relatively mild, managed mostly with home care, and involved limited formal treatment, the court awarded $35,000.00 for actual pain and suffering only, paid through counsel's IOLTA account.