Vanessa Garris v. HHS - Hepatitis B, multiple sclerosis (2025)

Filed 2022-04-28Decided 2025-11-18Vaccine Hepatitis B
denied

Case summary [AI summaries can sometimes make mistakes]

On April 28, 2022, Vanessa Garris filed a petition for compensation under the National Vaccine Injury Compensation Program, alleging that she suffered multiple sclerosis (MS) as a result of receiving a hepatitis B vaccine on February 10, 2020. Petitioner, then 29 years old, reported experiencing neurological symptoms including dizziness, numbness, headache, and slurred speech approximately three weeks after vaccination.

Initial MRIs revealed lesions concerning for demyelination, and she was diagnosed with acute disseminated encephalomyelitis (ADEM), with a neurologist opining it was likely secondary to the vaccine. However, subsequent evaluations led to a diagnosis of relapsing-remitting multiple sclerosis (MS).

Petitioner argued that the hepatitis B vaccine could cause or aggravate MS, citing theories of molecular mimicry and studies suggesting a possible association. Respondent argued that the scientific evidence did not support a causal link between the hepatitis B vaccine and MS, and that Petitioner's MS likely predated the vaccination.

Petitioner's expert, Dr. Darin Okuda, opined that the hepatitis B vaccine could cause MS through molecular mimicry, citing homologies between hepatitis B surface antigen and myelin components, and referencing studies such as Hernan and Bogdanos.

Respondent's experts, Dr. Michael Sweeney and Dr.

William Hawes, countered that the scientific literature did not support a causal link between the hepatitis B vaccine and MS, and that the proposed molecular mimicry mechanism was not sufficiently established for MS. They highlighted that studies like Rutschmann, DeStefano, and Sestili found no association, and that MOGAD, while related, is a distinct entity from MS.

The Special Master, Brian H. Corcoran, denied entitlement.

He found that Petitioner failed to establish by a preponderance of the evidence that the hepatitis B vaccine can cause MS (Althen prong one). The Special Master noted that while molecular mimicry was a proposed theory, the evidence, including the Bogdanos study, did not confirm a pathogenic link to MS, and that MS is a chronic, insidious disease distinct from acute demyelinating conditions more commonly associated with vaccines.

Furthermore, the Special Master found that Petitioner failed to establish that the vaccine caused her MS because the record supported the conclusion that her MS likely preceded vaccination, as evidenced by pre-vaccination lesions on MRI (Althen prong two). The Special Master also addressed the possibility of significant aggravation of a pre-existing condition, but found that Petitioner had not established this claim either, noting that MS flares are intrinsic to the disease's natural course and that the evidence did not support the vaccine as a cause of aggravation in this case.

The case was dismissed on the existing record without a hearing.

Theory of causation

Hepatitis B vaccine on February 10, 2020, age 29, followed about three weeks later by neurologic symptoms and multiple sclerosis diagnosis. DENIED. Petitioner relied on Dr. Darin Okuda and molecular mimicry involving hepatitis B surface antigen and myelin proteins. Respondent disputed the theory and case-specific sequence. Special Master Corcoran denied entitlement August 19, 2025; the Court of Federal Claims sustained the denial on November 18, 2025.

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