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

Anna Davis filed a petition for compensation under the National Vaccine Injury Compensation Program, alleging she suffered a shoulder injury related to vaccine administration (SIRVA) after receiving an influenza vaccine on October 31, 2018. She claimed this was a Table injury.

The case was filed on July 15, 2021. The respondent contested entitlement, arguing that Ms.

Davis failed to demonstrate that she suffered the residual effects of her injury for more than six months after vaccination, as required by the Act. The medical records show Ms.

Davis sought treatment for left shoulder pain two weeks after her vaccination. She reported improvement by January 23, 2019, and her range of motion had improved since her initial visit.

She then had a gap in treatment for nearly seven months, during which time her symptoms and MRI findings changed, and she was assessed with a new diagnosis of adhesive capsulitis. The court found that Ms.

Davis did not establish the statutory severity requirement because her treatment was limited to less than three months, she reported feeling better at her January 2019 visit, and she had a significant gap in treatment with subsequent changes in her condition. Therefore, the court dismissed her claim for insufficient evidence.