Roosevelt Poore v. HHS - Influenza, right shoulder injury related to vaccine administration (SIRVA) (2025)
Case summary [AI summaries can sometimes make mistakes]
On January 11, 2021, Roosevelt Poore filed a petition alleging that an influenza vaccination on October 10, 2020 caused a right shoulder injury related to vaccine administration. The record initially contained confusion about the injection arm, but a corrected record filed in May 2021 identified the right arm.
Respondent opposed entitlement, arguing that Mr. Poore had not shown pain onset within 48 hours, pain limited to the vaccinated shoulder, or residual effects lasting more than six months.
Chief Special Master Brian H. Corcoran found the record sufficient.
On November 5, 2020, Mr. Poore reported soreness after the shot followed by worsening difficulty using the right upper extremity about two weeks later.
He later explained that he delayed physical therapy during the COVID-19 pandemic and tried to manage the shoulder conservatively. The decision treated those facts as enough for Table SIRVA entitlement, while noting that the injury appeared mild and that the treatment delay would matter when damages were assessed.
On September 30, 2025, Chief Special Master Corcoran granted entitlement. The case remains in the damages phase, and no compensation amount has been awarded in the public ruling.
Theory of causation
Influenza vaccine, October 10, 2020, right SIRVA. ENTITLEMENT GRANTED; damages pending. Respondent disputed severity, 48-hour onset, and pain limited to the vaccinated shoulder. Chief Special Master Corcoran credited corrected right-arm vaccination records, a November 5 report that soreness began after the shot and worsened two weeks later, later declarations, and the COVID-era delay in PT. He found Table SIRVA but noted a mild injury relevant to damages. Decision September 30, 2025. Attorney Michael McLaren; respondent Ryan Pyles.
Source PDFs
USCOURTS-cofc-1_21-vv-00470