Chih-Jung Chen v. HHS - Influenza, shoulder injury related to vaccine administration (SIRVA) (2025)

Chih-Jung Chen, an adult, received an influenza vaccine on October 10, 2020. Within hours, she developed left arm pain that persisted and worsened over the following months, leading to a diagnosis of shoulder injury related to vaccine administration (SIRVA).

Her medical records documented pain and limited range of motion in her left shoulder, attributed to the vaccination. She underwent 21 physical therapy sessions over several months, reporting significant improvement by the end of her treatment.

The respondent argued that the onset of pain was not within the 48-hour window required for a Table claim. However, the court found that the evidence, including her own declarations and medical records linking the pain to the vaccination, preponderantly established that her pain began within 48 hours of the injection.

The court also found that she met the remaining criteria for a Table SIRVA claim, including no prior history of shoulder issues and that her symptoms persisted for more than six months. The court awarded Chih-Jung Chen $55,000.00 for pain and suffering and $192.96 for out-of-pocket medical expenses, totaling $55,192.96.