B.H.B. v. HHS - Influenza, type 1 narcolepsy (2025)

On February 16, 2023, Jennifer and Michael Barrios filed a petition on behalf of their minor child, B.H.B., alleging that influenza vaccines administered on September 24, 2020 and October 27, 2020 caused type 1 narcolepsy. Within about a month of the second vaccination, the parents observed that B.H.B.'s alertness decreased.

By December 2020, B.H.B. had an episode of extreme fatigue and lethargy that led to emergency care and further evaluation. Sleep specialist Dr.

Emmanuel Mignot followed B.H.B. in 2021 and 2022. After sleep studies, he concluded that B.H.B. had classical type 1 narcolepsy and wrote that the influenza vaccines plausibly caused it.

Dr. Mignot recognized that B.H.B.'s young age was unusual but not exceptional, and he relied in part on science connecting narcolepsy to Pandemrix, an adjuvanted H1N1 influenza vaccine used in Europe.

He also acknowledged that studies had not shown an increased narcolepsy risk after influenza vaccines other than Pandemrix. Chief Special Master Corcoran had previously rejected similar claims involving the non-adjuvanted influenza vaccines typically administered in the United States.

He ordered petitioners to show cause and allowed them to consult an expert, but directed them to identify new scientific or medical findings rather than submit a full report. Petitioners consulted Dr.

Michael Lacey, who criticized the Duffy study and argued that neurologic autoimmune phenomena can follow infections and vaccinations, but the Chief Special Master found the submission did not provide new evidence overcoming prior decisions. On August 22, 2024, the Chief Special Master dismissed the petition, finding that petitioners had not shown that the non-adjuvanted U.S. influenza vaccine can cause narcolepsy.

Judge Edward H. Meyers denied review in an opinion first issued February 18, 2025 and reissued publicly on March 11, 2025, holding that the Special Master did not abuse his discretion by relying on prior Program experience or by resolving the case without a filed expert report.

No compensation was awarded.