Lenka Valentine v. HHS - Influenza, shoulder injury related to vaccine administration (SIRVA) (2025)

Lenka Valentine filed a petition for compensation under the National Vaccine Injury Compensation Program, alleging she suffered a shoulder injury related to vaccine administration (SIRVA) as a result of an influenza vaccine received on November 12, 2020. The parties negotiated but reached an impasse, leading to a ruling on entitlement and damages.

Valentine received the flu vaccine on November 12, 2020. She reported right shoulder pain to an orthopedist nearly two months later, stating the pain began about two months prior and was related to the vaccine, which she believed was administered in her right arm.

She also noted on a physical therapy intake form that her issues began in November 2020, post-flu shot, and at her PT evaluation, she reported pain began one day after vaccination. Respondent argued that Valentine had not established that her pain began within 48 hours of vaccination, as she did not seek treatment until almost two months later.

The court found that the evidence preponderantly supported that the vaccine was administered in her right arm and that her shoulder pain likely began within 48 hours of vaccination, despite the treatment delay. The court also found that Valentine met the remaining SIRVA criteria and statutory requirements, establishing entitlement to compensation.

For damages, Valentine sought $65,000 for pain and suffering, while Respondent proposed no more than $20,000. The court awarded Valentine $45,000 for actual pain and suffering, finding her SIRVA to be on the milder side and resolved within approximately 11 months, considering comparable cases and the evidence presented.