Elizabeth Flores v. HHS - Influenza, left shoulder injury related to vaccine administration (SIRVA) (2026)

Elizabeth Flores filed a petition alleging that she suffered a left shoulder injury related to vaccine administration (SIRVA) as a result of an influenza vaccine administered on November 17, 2023. The respondent argued that the petitioner's medical records did not establish that the injury began within 48 hours of vaccination, as required for a Table SIRVA claim.

The petitioner's medical records consistently indicated that her shoulder pain began shortly after the vaccination. Although she delayed seeking treatment for over two months, the court found that this delay did not preclude establishing Table-consistent onset, citing precedent where longer delays were accepted.

The court found that the petitioner provided preponderant evidence that the onset of her shoulder pain occurred within 48 hours of vaccination. The case is proceeding to determine damages.