Adam Recla v. HHS - Influenza, right shoulder injury related to vaccine administration (SIRVA) (2025)
Case summary [AI summaries can sometimes make mistakes]
On January 30, 2025, Adam Recla filed a petition alleging that an influenza vaccination on November 9, 2023 caused a shoulder injury related to vaccine administration. Respondent conceded entitlement in a Rule 4(c) report filed on September 10, 2025.
Respondent agreed that Mr. Recla's injury was consistent with SIRVA as defined by the Vaccine Injury Table.
The concession stated that he had no history of right-shoulder pain, inflammation, or dysfunction before vaccination; pain occurred within 48 hours; pain and reduced range of motion were limited to the vaccinated shoulder; no other condition explained the pain; and residual effects lasted more than six months. Chief Special Master Brian H.
Corcoran granted entitlement on September 12, 2025. Damages were resolved by proffer, and on September 17, 2025 Mr.
Recla was awarded $47,500.00 for pain and suffering, paid through counsel's IOLTA account. The public rulings do not provide a detailed treatment chronology.
Theory of causation
Influenza vaccine, November 9, 2023, right Table SIRVA. ENTITLEMENT GRANTED and COMPENSATED. Respondent conceded no prior right-shoulder pain/dysfunction, pain within 48 hours, pain/reduced ROM limited to vaccinated shoulder, no alternative condition, residual effects >6 months, and legal prerequisites. Entitlement September 12, 2025; damages September 17, 2025. Award: $47,500 pain and suffering, all Section 15(a) damages, ACH to counsel IOLTA. Petitioner competent adult. Attorney Jonathan Groth; respondent Elizabeth Andary.
Source PDFs
USCOURTS-cofc-1_25-vv-00173