Rhonda Boyd v. HHS - Influenza, shoulder injury related to vaccine administration (SIRVA) (2025)
Case summary [AI summaries can sometimes make mistakes]
On May 5, 2021, Rhonda Boyd filed a petition alleging that an influenza vaccine administered on September 23, 2020 caused a shoulder injury related to vaccine administration. The entitlement dispute centered on proof of onset.
Ms. Boyd relied on affidavits to support shoulder pain within the SIRVA timeframe, but the medical record documented her first relevant appointment almost four months after vaccination and contained different descriptions of left- and right-sided shoulder symptoms and possible impingement or arthritis.
Special Master Katherine E. Oler found that the later affidavits did not adequately explain the gap in contemporaneous medical records.
Ms. Boyd moved to dismiss the case in September 2025.
On September 16, 2025, Special Master Oler dismissed the petition, finding that entitlement had not been proven on either a Table SIRVA theory or an off-Table causation theory. No compensation was awarded.
Theory of causation
Influenza vaccine September 23, 2020 allegedly causing SIRVA; adult, exact age not stated. DISMISSED. Main failure was onset/causation proof: first relevant treatment nearly four months after vaccination, records reflected varying left/right shoulder complaints and possible impingement/arthritis, and affidavits did not overcome contemporaneous record gaps. SM Katherine E. Oler; petition May 5, 2021; dismissal September 16, 2025.
Source PDFs
USCOURTS-cofc-1_21-vv-01323