Miranda Chu v. HHS - Tdap, shoulder injury related to vaccine administration (SIRVA) (2026)

On April 12, 2021, Miranda Chu filed a petition for compensation under the National Vaccine Injury Compensation Program, alleging she suffered a Shoulder Injury Related to Vaccine Administration (SIRVA) following a Tdap vaccine received on July 21, 2015. She was 19 years old at the time of vaccination and reported no prior history of shoulder pain or dysfunction.

Nine days after the vaccination, on July 30, 2015, she began experiencing pain, numbness, and reduced range of motion in her left shoulder and elbow, with tingling down her arm. Over the subsequent years, she underwent numerous medical evaluations and treatments, including MRIs, ultrasounds, physical therapy, arthroscopy, and two embolization procedures for a diagnosed vascular malformation (AVM) in her shoulder.

Despite these interventions, her pain persisted. A physiatrist evaluated her in June 2019 and diagnosed two separate pain generators: SIRVA and thoracic outlet syndrome/C8 pattern symptoms potentially related to the AVM.

The Chief Special Master dismissed the claim on July 18, 2025, finding that Ms. Chu failed to establish the criteria for a Table SIRVA claim.

Specifically, the Special Master determined her symptoms were not limited to the shoulder (failing QAI 3) and that the vascular malformation presented a potential alternative explanation for her symptoms (failing QAI 4). The Special Master also concluded that any off-Table, causation-in-fact claim was time-barred due to the late filing of the petition.

On January 28, 2026, the U.S. Court of Federal Claims, in a reported opinion by Judge Ryan T.

Holte, granted Ms. Chu's motion for review.

The court vacated the Special Master's decision, finding that the Special Master's analysis of QAI 3 and QAI 4 lacked a rational basis and was arbitrary and capricious. The court remanded the case to the Chief Special Master for further proceedings, directing a new entitlement decision within 90 days.

The court noted that the Special Master's interpretation of QAI 3, which seemed to preclude claims with symptoms outside the shoulder, was contrary to law and precedent. The court also found the Special Master erred in evaluating QAI 4 by not adequately considering the evolution of medical diagnoses and potentially substituting his own judgment for that of treating physicians without sufficient justification or expert testimony.

The court did not rule on entitlement but remanded for further consideration.