Doyle Manning v. HHS - Influenza, shoulder injury related to vaccine administration (SIRVA) (2026)

Doyle Manning filed a petition for compensation under the National Vaccine Injury Compensation Program, alleging he suffered a shoulder injury related to vaccine administration (SIRVA) following an influenza vaccine received on October 9, 2021. He also received a Covid-19 vaccine on the same day.

Mr. Manning sought treatment approximately seven weeks after vaccination, reporting pain in his left shoulder.

Medical records from his urgent care visit and orthopedic consultations indicated full active and passive range of motion, though he experienced pain with certain movements. His own affidavits and those of his husband and friend stated that his movement limitations were due to pain avoidance rather than actual restricted range of motion.

The respondent contested entitlement, arguing Mr. Manning had not established limited or reduced range of motion, a key criterion for a Table SIRVA claim.

The court found that while Mr. Manning may have experienced pain, he did not preponderantly establish limited or reduced range of motion as required by the Vaccine Injury Table criteria.

Therefore, his Table SIRVA claim was dismissed. The court noted that he might have a causation-in-fact claim for another injury and the case would be transferred out of the Special Processing Unit.