Amy Gray v. HHS - Influenza, shoulder injury related to vaccine administration (SIRVA) (2025)
Case summary [AI summaries can sometimes make mistakes]
On August 9, 2021, Amy Gray filed a petition, later amended in August 2022, alleging that an influenza vaccine administered in her left arm on October 7, 2020 caused a shoulder injury related to vaccine administration. Entitlement turned largely on onset and severity.
Ms. Gray's first documented shoulder care was on December 21, 2020, when she reported pain that began just after the flu shot, constant discomfort rated 3 out of 10 with flares to 7 or 8, and worse pain with movement.
A January 2021 MRI showed bursitis, a partial-thickness supraspinatus tear, mild AC-joint degenerative change, and a small effusion. Orthopedic records described limited range of motion, impingement-type findings, and home physical therapy; later diabetes and cardiology records contained little shoulder discussion.
Ms. Gray and supporting witnesses described shoulder pain beginning within days of vaccination and continuing despite limited insurance and financial barriers to treatment.
Respondent disputed whether the evidence proved timely onset and six-month severity, pointing to the treatment gap and unrelated medical records. Chief Special Master Brian H.
Corcoran credited the declarations with the contemporaneous record and found entitlement on August 18, 2025. On September 9, 2025, Chief Special Master Corcoran awarded $32,500.00 for pain and suffering and $238.25 in unreimbursed expenses, for a total of $32,738.25.
Theory of causation
Influenza vaccine October 7, 2020 causing SIRVA; adult, exact age not stated; onset credited within 48 hours despite first treatment December 21, 2020. ENTITLEMENT GRANTED; COMPENSATED. Evidence included declarations, December 2020 pain history, January 2021 MRI with bursitis/partial-thickness supraspinatus tear/mild AC degenerative change/small effusion, limited ROM, home PT, and treatment gaps from cost/insurance. Respondent challenged onset and severity. Award $32,500 pain/suffering + $238.25 expenses = $32,738.25. Chief SM Brian H. Corcoran; petition August 9, 2021; amended petition August 19, 2022; entitlement August 18, 2025; damages September 9, 2025.