Kimberly Palmer v. HHS - Influenza, shoulder injury related to vaccine administration (SIRVA) (2025)

Kimberly Palmer filed a petition for compensation under the National Vaccine Injury Compensation Program, alleging that she suffered a shoulder injury related to vaccine administration (SIRVA) as a result of an influenza vaccination received on September 20, 2022. She further alleged that she suffered residual effects of her injury for more than six months.

The respondent, the Secretary of Health and Human Services, filed a Rule 4(c) report conceding that Palmer is entitled to compensation. The respondent stated that the Division of Injury Compensation Programs concluded that Palmer's alleged injury is consistent with SIRVA as defined by the Vaccine Injury Table, noting that she had no prior history of shoulder issues, pain occurred within 48 hours post-vaccination, and the pain and reduced range of motion were limited to the injection site.

The respondent also confirmed that Palmer suffered residual effects for more than six months and that no other condition explained her symptoms. Based on the respondent's concession and the evidence of record, the Chief Special Master found that Palmer is entitled to compensation.

The case is proceeding to determine the award amount.