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

Mark Humpfer, born in 1956, received an influenza vaccine on November 8, 2020. He filed a petition alleging a shoulder injury related to vaccine administration (SIRVA) as a Table injury.

Approximately two months later, he sought treatment for right arm pain that had started after the vaccination. Medical records documented pain and limited range of motion, initially noted as medial biceps tenderness by his primary care physician, and later described by an orthopedist as sharp shooting pains starting in the biceps area and shooting down to the elbow, with shoulder impingement syndrome and bicipital tendinitis diagnosed.

Physical therapy records also noted pain throughout the upper arm and elbow, with tenderness throughout the biceps. The court dismissed the Table SIRVA claim because the evidence showed the pain was not limited to the shoulder, but also occurred in the biceps and elbow, failing to meet a key requirement of the Table definition for SIRVA.

The court noted that a possibly meritorious causation-in-fact claim might remain, but the Table claim was dismissed. The decision was issued on April 8, 2025.