Diane M. Hiatt v. HHS - Influenza, left shoulder injury related to vaccine administration (SIRVA) (2025)

On September 11, 2023, Diane M. Hiatt, a 76-year-old retired nurse practitioner, filed a petition alleging that an influenza vaccination administered on September 10, 2022 caused a left shoulder injury related to vaccine administration.

The case turned on the Table SIRVA onset requirement. Ms.

Hiatt had no prior left-shoulder problems. She did not seek formal treatment until January 25, 2023, more than four months after vaccination, but her declaration and intake questionnaire stated that pain began the day after the shot, that the injection had been given too high, and that the pain never resolved.

Chief Special Master Corcoran credited that account, noting that her medical background made delayed formal treatment more understandable because medical professionals may self-treat musculoskeletal injuries. He found onset within forty-eight hours, symptoms limited to the vaccinated shoulder, no alternative explanation, and more than six months of residual effects.

Damages were decided in the same May 13, 2025 ruling. Ms.

Hiatt sought $45,000.00 for pain and suffering, emphasizing lifelong athletic activity and daily pain. Respondent proposed a lower award, pointing to the delay in treatment and the limited course of care.

The Special Master characterized the injury as very mild: eight physical-therapy sessions, one steroid injection, no surgery, and limited treatment. He awarded $25,000.00 for pain and suffering only.