Ryan Carroll v. HHS - Influenza, right shoulder injury related to vaccine administration (SIRVA) (2026)

Ryan Carroll filed a petition alleging a right shoulder injury related to vaccine administration (SIRVA) after receiving an influenza vaccine on October 4, 2018. The initial ruling found that Mr.

Carroll had established pain onset within 48 hours of vaccination, but failed to provide sufficient evidence of limited range of motion (ROM) or six months of sequelae required for a Table SIRVA claim. The case was ordered to show cause why it should not be dismissed.

In the subsequent ruling, the court found that while Mr. Carroll had established the six-month severity requirement, he failed to demonstrate limited ROM.

Therefore, his Table SIRVA claim was dismissed. The court noted that a non-Table claim for causation-in-fact might still be viable, but given the mild nature and short duration of symptoms, any compensation would not be significant.

The parties were encouraged to attempt settlement again.