Tamara Cook v. HHS - Influenza, rash, consistent with urticaria versus bullous pemphigoid (2025)

Tamara Cook filed a petition alleging she developed a rash, consistent with urticaria or bullous pemphigoid, caused by an influenza vaccine received on February 28, 2020. The respondent argued entitlement should be denied, noting that medical providers variously diagnosed her rash as a discoid lupus flare, a varicella-like rash related to COVID-19, or possibly cutaneous lupus erythematosus, and that she had a history of systemic lupus erythematosus and an intermittent photosensitive rash.

The respondent also stated that no medical expert report was provided to causally link the flu vaccination to her rash, and none of her treating physicians attributed the rash to the vaccination. The petitioner subsequently indicated she had retained an expert and was given a deadline to file a report.

However, the petitioner then filed a motion to dismiss, stating that an investigation demonstrated she would be unable to prove entitlement to compensation. The respondent did not oppose the motion.

The Special Master granted the motion, dismissing the petition due to insufficient evidence to meet the burden of proof.