Jennifer Puckett v. HHS - Influenza, Stevens-Johnson syndrome (2024)
Case summary [AI summaries can sometimes make mistakes]
Jennifer Puckett, born in 1995, filed a petition for compensation on March 29, 2021, alleging that an influenza vaccine administered on November 12, 2018, caused her to develop Stevens-Johnson syndrome (SJS). Ms.
Puckett was 17 years old at the time of the vaccination. She reported developing a rash two days after the vaccination and was admitted to Jackson Hospital with a concern for SJS.
Her treating physicians noted potential causes including the flu shot or a tuberculosis (PPD) skin test, which she also received on the same day. As her condition progressed, she was transferred to the University of Alabama Hospital, where she was treated for SJS.
The diagnosis of SJS was not disputed in the litigation. Ms.
Puckett submitted medical records, photographs of her condition, and several articles discussing vaccines and SJS. However, she did not provide an expert medical opinion to establish a causal link.
The Secretary of Health and Human Services argued that Ms. Puckett could not prove causation, noting the concurrent PPD test made it difficult to isolate the flu vaccine as the sole cause.
The Special Master, Christian J. Moran, reviewed the evidence, including numerous notes from treating physicians who commented on potential causes.
While some physicians attributed the SJS to the flu vaccination, others suggested the PPD test or were unclear. A dermatologist noted that the inciting medication was unclear and did not favor the PPD or influenza vaccine as causative at that time.
The Special Master noted that Ms. Puckett failed to provide a medical theory or expert opinion that persuasively distinguished the flu vaccine as the cause over the PPD test.
The public decision does not describe the specific onset of symptoms beyond a rash developing over two days, nor does it detail all treatments or the specific mechanism by which the flu vaccine might cause SJS. Petitioner was represented by Laura J.
Levenburg, and respondent was represented by Nina Y. Ren.
Special Master Christian J. Moran issued a decision denying compensation on June 25, 2024, finding that Ms.
Puckett failed to establish by a preponderance of the evidence that the flu vaccine caused her SJS, particularly because she could not isolate the vaccine as the cause over the PPD test. The case was litigated based on the existing record, with neither party requesting a hearing.
The decision was made publicly accessible.
Theory of causation
Petitioner Jennifer Puckett, vaccinated with an influenza vaccine on November 12, 2018, at age 17, alleged this caused Stevens-Johnson syndrome (SJS). The public decision does not detail a specific medical theory of causation or name an expert. Petitioner submitted articles, including one by Su et al. analyzing VAERS reports, which suggested a potential link between influenza vaccines and SJS, with 71% of SJS cases showing onset within 3 days of vaccination. The Special Master found this article minimally reliable and noted the low incidence rate of SJS after flu vaccination reported therein. Petitioner also relied on treating physicians' notes, some of which mentioned the flu shot as a potential cause, while others implicated a PPD test administered on the same day. The Secretary argued that the concurrent PPD test made it impossible to isolate the flu vaccine as the cause. The Special Master focused on the views of dermatologists, who did not conclude the flu vaccine was the most likely cause. Ultimately, the Special Master, Christian J. Moran, denied compensation on June 25, 2024, finding Petitioner failed to meet the Althen standard by not persuasively distinguishing the flu vaccine as the cause of SJS over the PPD test, despite establishing a plausible temporal relationship. Petitioner was represented by Laura J. Levenburg; Respondent by Nina Y. Ren. The theory was considered 'Off-Table'.