VICP Registry Case Source Bundle
Canonical URL: https://vicp-registry.org/case/USCOURTS-cofc-1_25-vv-02037
Package ID: USCOURTS-cofc-1_25-vv-02037
Petitioner: MARRIEA LAYTON
Filed: 2025-12-01
Decided: 2026-06-29
Vaccine: influenza
Vaccination date: 2024-09-13
Condition: shoulder injury related to vaccine administration (SIRVA)
Outcome: entitlement_granted_pending_damages
Award amount USD: 

AI-assisted case summary:
Marriea Layton filed a petition for compensation under the National Vaccine Injury Compensation Program on December 1, 2025, alleging that an influenza vaccine administered on September 13, 2024, caused her to suffer a shoulder injury related to vaccine administration (SIRVA). She stated that she received the vaccine in the United States, suffered residual effects for more than six months, and had no prior award or settlement for her injury. Respondent filed a Rule 4(c) report on June 18, 2026, conceding that Petitioner is entitled to compensation. Respondent noted that Petitioner had no prior shoulder issues, the pain occurred within 48 hours of vaccination, was limited to the vaccination arm, and no other condition explained the symptoms. Petitioner also met the six-month residual effects requirement. Based on the Respondent's concession and the record, Chief Special Master Corcoran found Petitioner entitled to compensation.

Theory of causation field:
Table

Public staged source text:

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DOCUMENT 1: USCOURTS-cofc-1_25-vv-02037-0
Date issued/filed: 2026-08-07
Pages: 2
Docket text: PUBLIC ORDER/RULING (Originally filed: 06/29/2026) regarding 16 Ruling on Entitlement Signed by Chief Special Master Brian H. Corcoran. (ppa) Service on parties made.
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Case 1:25-vv-02037-UNJ Document 20 Filed 08/07/26 Page 1 of 2
In the United States Court of Federal Claims
OFFICE OF SPECIAL MASTERS
No. 25-2037V
MARRIEA LAYTON,
Chief Special Master Corcoran
Petitioner,
v. Filed: June 29, 2026
SECRETARY OF HEALTH AND
HUMAN SERVICES,
Respondent.
Matthew B Bernstein, Green & Schafle LLC, Philadelphia, PA, for Petitioner.
Naseem Kourosh, U.S. Department of Justice, Washington, DC, for Respondent.
RULING ON ENTITLEMENT1
On December 1, 2025, Marriea Layton filed a petition for compensation under the
National Vaccine Injury Compensation Program, 42 U.S.C. §300aa-10, et seq.2 (the
“Vaccine Act”). Petitioner alleges that an influenza (“flu”) vaccine administered to her on
September 13, 2024 caused her to suffer a shoulder injury related to vaccine
administration (“SIRVA”), as defined in the Vaccine Injury Table (42 C.F.R. § 100.3).
Petition at 1. Petitioner further alleges that she received the vaccine in the United States,
that she suffered the residual effects of her injury for more than six months, and that there
has been no prior award or settlement of a civil action on her behalf as a result of her
injury. See Petition at ¶¶ 3, 20-21, 24. The case was assigned to the Special Processing
Unit of the Office of Special Masters.
1 Because this Ruling contains a reasoned explanation for the action taken in this case, it must be made
publicly accessible and will be posted on the United States Court of Federal Claims' website, and/or
at https://www.govinfo.gov/app/collection/uscourts/national/cofc, in accordance with the E-Government
Act of 2002. 44 U.S.C. § 3501 note (2018) (Federal Management and Promotion of Electronic Government
Services). This means the Ruling will be available to anyone with access to the internet. In accordance
with Vaccine Rule 18(b), Petitioner has 14 days to identify and move to redact medical or other information,
the disclosure of which would constitute an unwarranted invasion of privacy. If, upon review, I agree that
the identified material fits within this definition, I will redact such material from public access.
2 National Childhood Vaccine Injury Act of 1986, Pub. L. No. 99-660, 100 Stat. 3755. Hereinafter, for ease
of citation, all section references to the Vaccine Act will be to the pertinent subparagraph of 42 U.S.C. §
300aa (2018).

Case 1:25-vv-02037-UNJ Document 20 Filed 08/07/26 Page 2 of 2
On June 18, 2026, Respondent filed his Rule 4(c) report in which he concedes that
Petitioner is entitled to compensation in this case. Respondent’s Rule 4(c) Report at 1.
Specifically, Respondent states that he
recommends that petitioner be found entitled to compensation for a Table
SIRVA Petitioner had no history of pain, inflammation, or dysfunction of her
left shoulder prior to vaccination that would explain petitioner’s post-
vaccination symptoms; shoulder pain occurred within 48 hours after receipt
of an intramuscular vaccination; shoulder pain and reduced ROM were
limited to the side in which the vaccine was administered; and no other
condition or abnormality has been identified to explain petitioner’s shoulder
pain. 42 C.F.R. §§ 100.3(a)(XIV)(B), (c)(10). Additionally, petitioner suffered
the residual effects of her condition for more than six months. See 42 U.S.C.
§ 300aa-11(c)(1)(D)(i). Therefore, based on the current record, petitioner
has satisfied all requirements for compensation under the Act. See 42
U.S.C. § 300aa-13(a)(1)(A-B).
Id. at 5-6.
In view of Respondent’s position and the evidence of record, I find that
Petitioner is entitled to compensation.
IT IS SO ORDERED.
s/Brian H. Corcoran
Brian H. Corcoran
Chief Special Master
2