Michael Barnes v. HHS - Influenza, shoulder injury related to vaccine administration (SIRVA) (2026)
Case summary [AI summaries can sometimes make mistakes]
On November 8, 2022, Michael Barnes filed a petition seeking compensation under the National Vaccine Injury Compensation Program. He alleged that he suffered a Table shoulder injury related to vaccine administration after receiving influenza and pneumococcal vaccines on November 6, 2021.
The public text is partly degraded by OCR, but the readable portions show that the case turned on a disputed SIRVA entitlement issue. Mr.
Barnes had received both vaccines in his right arm. In December 2021, his primary care physician recorded that he reported his arm had been painful for the last month and that he associated the pain with the pneumococcal vaccine.
In February 2022, he again attributed right arm pain to the pneumococcal vaccination, while also noting that he had received another vaccine in the left arm. An orthopedic visit with Dr.
Jonathan Greis recorded that the pain began in November 2021, that it was sudden, and that Mr. Barnes had significant pain and disability in the right shoulder.
Respondent opposed compensation. After briefing and an expedited hearing, Chief Special Master Brian H.
Corcoran ruled that the medical records and testimony were sufficient to establish a Table SIRVA. The ruling granted entitlement on February 23, 2026, with damages left for later resolution.
No compensation award had been entered in the public text reviewed for this update.
Theory of causation
Adult petitioner; influenza and pneumococcal vaccines November 6, 2021; alleged Table SIRVA/right shoulder injury. ENTITLEMENT GRANTED, damages pending. Respondent opposed entitlement; Chief SM Corcoran resolved the disputed SIRVA issue after briefing and an expedited hearing. Public text, partly degraded by OCR, describes post-vaccination right arm/shoulder pain documented by PCP and orthopedist Dr. Jonathan Greis, with sudden onset and significant right shoulder disability. Petition filed November 8, 2022; entitlement ruling internally filed February 23, 2026. No damages award in reviewed public text.
Source PDFs
USCOURTS-cofc-1_22-vv-01708