Isabel Zamora v. HHS - Influenza, chronic fatigue syndrome (2025)

Isabel Zamora filed a petition on June 1, 2021, alleging that an influenza vaccination administered on October 8, 2019, caused her to develop chronic fatigue syndrome. Ms.

Zamora, born in 1962, received the Flulaval influenza vaccine. She reported experiencing headaches and fatigue soon after the vaccination.

Her symptoms reportedly intensified, leading her to stop working in March 2020 and again on June 6, 2020, due to severe headaches, fatigue, and numbness in her fingers. A diagnosis of chronic fatigue syndrome was made on September 26, 2020, by a physician assistant.

Ms. Zamora was represented by attorneys Andrew Downing and later Courtney Jorgensen of Siri & Glimstad, LLP.

The respondent, the Secretary of Health and Human Services, was represented by Naseem Kourosh of the U.S. Department of Justice.

To support her claim, Ms. Zamora presented expert testimony from neurologist Dr.

Mitchell Miglis. Dr.

Miglis opined that the influenza vaccine caused Ms. Zamora's chronic fatigue syndrome, suggesting a possible mechanism of molecular mimicry, with an onset between October and December 2019.

The respondent presented expert testimony from rheumatologist Dr. Roland Staud, who opined that Ms.

Zamora's chronic fatigue syndrome predated the vaccination and that there is no scientifically proven connection between influenza vaccination and chronic fatigue syndrome. Special Master Christian J.

Moran reviewed the evidence and arguments. He found that Ms.

Zamora failed to establish that the influenza vaccine can cause chronic fatigue syndrome, which is a requirement under the first prong of the Althen standard for off-Table injuries. The Special Master noted the lack of scientific evidence supporting a causal link and the limitations of epidemiological studies and case reports.

He also found issues with the temporal relationship, as both experts placed the onset of symptoms before the vaccination. Dr.

Miglis placed the onset between October and December 2019, while Dr. Staud placed it even earlier.

The Special Master concluded that Ms. Zamora had not met her burden of proof for Althen prong one.

Ms. Zamora appealed the Special Master's decision to the Court of Federal Claims.

Senior Judge Loren A. Smith reviewed the case and affirmed the Special Master's decision.

The Court found that Special Master Moran did not apply a heightened standard of proof and that Ms. Zamora failed to meet her burden of proof under the Althen standard.

The Court agreed that the evidence did not support a causal link between the influenza vaccine and chronic fatigue syndrome, and that the temporal relationship was not established. The petition was denied, and no compensation was awarded.