Valerie Snaman Stout v. HHS - Influenza, shoulder injury related to vaccine administration (SIRVA) (2025)
Case summary [AI summaries can sometimes make mistakes]
On November 20, 2023, Valerie Snaman Stout filed a petition alleging that an influenza vaccination on November 13, 2021 caused a shoulder injury related to vaccine administration. She alleged a Table SIRVA, receipt of the vaccination in the United States, and residual effects lasting more than six months.
Respondent conceded entitlement in a Rule 4(c) report, stating that Ms. Stout had no history of right-shoulder pain, inflammation, or dysfunction before vaccination; that pain occurred within forty-eight hours; that pain and reduced range of motion were limited to the vaccinated shoulder; and that no other condition explained the shoulder pain.
Chief Special Master Brian H. Corcoran entered an entitlement ruling on November 21, 2024.
Damages were resolved by proffer. On June 27, 2025, Chief Special Master Corcoran awarded a lump sum of $72,536.70: $70,000.00 for pain and suffering and $2,536.70 for unreimbursed expenses.
A later CourtListener supplement appears to be garbled in staging text and was not used to change the injury award.
Theory of causation
Influenza vaccine on November 13, 2021, causing Table SIRVA; COMPENSATED after respondent conceded entitlement. Evidence credited in concession: no prior right shoulder dysfunction, onset within 48 hours, pain/reduced ROM limited to vaccinated shoulder, no alternative cause, severity over six months. Award $72,536.70 ($70,000 pain/suffering + $2,536.70 unreimbursed expenses). Chief SM Brian H. Corcoran, petition filed November 20, 2023; entitlement November 21, 2024; damages June 27, 2025. Attorney: Ramon Rodriguez III, Siri & Glimstad/Sands Anderson, Richmond VA.
Source PDFs
USCOURTS-cofc-1_23-vv-02010