Melissa Little v. HHS - Influenza, right shoulder injury related to vaccine administration (SIRVA) (2025)
Case summary [AI summaries can sometimes make mistakes]
On October 27, 2022, Melissa Little filed a petition, later amended on January 25, 2024, alleging that an influenza vaccine administered in her right arm on October 13, 2021 caused a shoulder injury related to vaccine administration. Ms.
Little first sought care on October 25, 2021, reporting right shoulder pain where she had received the flu vaccine twelve days earlier. In November 2021, she continued to report pain, mild limitation of motion, and infraspinatus tendinosis on MRI without a tear.
An orthopedist recorded constant right shoulder pain after the flu vaccine, difficulty dressing, sleeping, reaching, and later holding her young son. Treatment included anti-inflammatory medication, home exercises, delayed formal physical therapy because of COVID concerns and family caregiving, and ongoing follow-up.
By October 2022, the shoulder pain and restriction were described as resolved, though neck pain remained. Respondent moved to dismiss, arguing that Ms.
Little had not proven the six-month severity requirement. Chief Special Master Brian H.
Corcoran found the requirement barely satisfied, while noting that treatment gaps and a limited treatment course would affect damages. On November 25, 2025, he awarded $42,500.00 for pain and suffering and $176.16 in unreimbursed expenses, for a total lump sum of $42,676.16.
Theory of causation
Influenza vaccine October 13, 2021 causing right Table SIRVA; competent adult, exact age not stated. COMPENSATED after contested severity. First care twelve days later; records documented right shoulder pain at injection site, mild ROM limitation, MRI infraspinatus tendinosis without tear, orthopedic care, difficulty dressing/sleeping/reaching/holding child, delayed PT, and later resolution. Respondent challenged six-month severity; SM found it barely met. Award $42,500 pain/suffering + $176.16 expenses = $42,676.16. Chief SM Brian H. Corcoran; petition October 27, 2022; amended petition January 25, 2024; entitlement September 3, 2025; damages November 25, 2025.