Michael Erhart v. HHS - Influenza, left shoulder injury related to vaccine administration (“SIRVA”) (2026)

Michael Erhart, a 54-year-old self-employed guitar teacher, filed a petition for compensation under the National Vaccine Injury Compensation Program. He alleged that an influenza vaccine received on October 21, 2021, caused a left shoulder injury related to vaccine administration (SIRVA), which is a Table injury.

Petitioner's pre-vaccination medical history included degenerative disc disease, plantar fasciitis, and bilateral foot pain, but no history of shoulder pain. Approximately 12 days post-vaccination, he reported significant pain and difficulty lifting his left arm.

Medical records from January 2022 confirmed left shoulder pain, reduced range of motion, and tenderness, diagnosing him with left shoulder adhesive capsulitis and left upper arm pain, likely related to the flu vaccination. He underwent 16 physical therapy sessions, showing gradual improvement but still experiencing pain with overhead reaching at discharge.

Respondent contested entitlement, arguing the injury did not meet the six-month severity requirement. However, the Chief Special Master found that Petitioner met all the Qualifications and Aids to Interpretation for a Table SIRVA, including no prior shoulder condition, onset within 48 hours, pain limited to the left shoulder, and no other explanatory condition.

The court also found that despite discharge from physical therapy after just over five months, the residual effects likely persisted beyond the six-month threshold, satisfying the severity requirement. Therefore, Petitioner was found entitled to compensation, and a damages order was to be entered.