C.K. v. HHS - MMR, immune thrombocytopenic purpura (ITP) (2026)
Case summary [AI summaries can sometimes make mistakes]
On April 19, 2021, Abraham Klein and Shifra Kahan filed a petition on behalf of their minor child, C.K. They alleged that C.K. developed immune thrombocytopenic purpura (ITP) after receiving measles-mumps-rubella (MMR), influenza, and varicella vaccines on October 17, 2018.
The petition presented both a Table ITP theory and an alternative off-Table causation claim. Respondent challenged the Table claim.
The Vaccine Injury Table requires ITP to begin within the Table time window after MMR vaccination, and respondent argued that C.K.'s records placed onset too late. The contemporaneous medical records showed a January 2, 2019 pediatric visit for bruising over the lower left abdomen, scattered petechiae, and bruising of the chin and lower extremities.
The emergency-room history the same day recorded that the parents had first noticed the abdominal bruising the previous day. Those entries placed onset roughly 75 to 77 days after the MMR vaccine, outside the Table window.
Respondent also pointed to evidence of an intervening viral illness with fever between vaccination and ITP onset, which raised an exclusionary issue for the Table claim. Chief Special Master Brian H.
Corcoran dismissed the Table ITP claim on February 17, 2026. Petitioners confirmed that they had no additional medical evidence to offer on the Table timing issue, but they asked to continue pursuing a causation-in-fact claim.
The case therefore did not end with the ruling; the off-Table claim remained pending and was transferred out of the Special Processing Unit for further proceedings.
Source PDFs
USCOURTS-cofc-1_21-vv-01239