Kathy Frye v. HHS - Influenza, left shoulder injury related to vaccine administration (SIRVA) (2025)

On May 24, 2022, Kathy Frye filed a petition alleging that an influenza vaccine administered on October 2, 2019 caused a left shoulder injury related to vaccine administration. She was 67 years old at vaccination.

During the case, Ms. Frye died on April 2, 2025 of causes unrelated to the vaccine injury, and Sonya F.

Smith continued the matter as administrator of her estate. Respondent disputed entitlement, pointing to a vaccine record that listed the right arm and arguing that the public medical record did not prove the required severity.

Chief Special Master Brian H. Corcoran found the left-arm situs supported by medical records and a spouse statement describing the bandage location.

He also found limited range of motion from the November 20, 2019 orthopedic examination, which recorded reduced forward flexion and abduction with stiffness and pain, and from the December 10, 2019 physical therapy plan to restore active range of motion. On October 9, 2025, the Chief Special Master found that Ms.

Frye had established a Table SIRVA. On November 7, 2025, he awarded $106,558.08: $105,000.00 for past pain and suffering and $1,558.08 for past unreimbursed expenses.

The award was payable by ACH deposit to counsel's IOLTA account for prompt disbursement to Sonya Frye Smith as estate representative. Ms.

Frye was represented by Chellis Garcia of Maglio Christopher & Toale.