Irene Perkin v. HHS - Influenza, shoulder injury related to vaccine administration (SIRVA) (2026)
Case summary [AI summaries can sometimes make mistakes]
On September 30, 2022, Irene Perkin, then 73, filed a petition alleging that an influenza vaccine administered on November 3, 2020 caused a shoulder injury related to vaccine administration. Ms.
Perkin later stated that the vaccine was administered high and that she developed shooting pain by the next morning. Her husband also supported early onset.
But the contemporaneous medical records undercut the claim. A sleep-apnea telehealth visit two weeks later and a November 20, 2020 primary-care visit did not include a shoulder complaint.
The first documented shoulder visit was on June 24, 2021, more than seven months after vaccination, when she reported progressively worsening pain over six months. Treaters described arthritis, tendinopathy, severe primary osteoarthritis, and ankylosis.
Chief Special Master Brian H. Corcoran held that Ms.
Perkin had not proven onset within 48 hours or within a medically reasonable period for causation-in-fact. The delayed records and osteoarthritis evidence defeated the claim.
The case was dismissed on January 12, 2026, with no compensation awarded.
Theory of causation
Influenza vaccine November 3, 2020 at age 73 allegedly causing SIRVA. DISMISSED. Petitioner and husband alleged early onset, but contemporaneous records omitted shoulder complaints and first shoulder visit was June 24, 2021. Treaters noted arthritis/tendinopathy/severe primary osteoarthritis/ankylosis. Chief SM Corcoran found onset not proven for Table or causation-in-fact. Petition September 30, 2022; decision January 12, 2026.
Source PDFs
USCOURTS-cofc-1_22-vv-01413