{"package_id":"USCOURTS-cofc-1_92-vv-00478","decision_granule_id":"USCOURTS-cofc-1_92-vv-00478-cl6645532","petitioner_identifier":"Patricia Lynn Johnson","is_minor":0,"age_at_vaccination":34.0,"age_unit_raw":"years","vaccine_type":"rubella","vaccination_date":"1989-12-14","condition_raw":"fibromyalgia syndrome and chronic rubella-associated joint pain","condition_category":"other","autism_spectrum_adjacent":0,"outcome":"denied","award_amount_usd":null,"decision_date":"1995-07-18","extraction_version":"gemini-v2","extracted_at":"2026-04-30T13:54:31.600034+00:00","number_of_concurrent_vaccines":1,"dose_number":null,"time_to_onset_days":10,"theory_of_causation":"Rubella vaccine, December 14, 1989, age ~34. Alleged arthropathy + fibromyalgia syndrome (FMS). Part of Omnibus Proceeding (6-part rubella arthropathy test). DISMISSED — SM denied causation: symptoms were reverse of typical rubella arthropathy pattern; FMS preceded arthropathic symptoms. CFC Senior Judge Gibson (Jul 18, 1995): affirmed — correct § 13(a)(1)(A) preponderance standard applied; § 13(a)(2)(A) idiopathic argument moot (already failed causation-in-fact); Dr. Tingle report error harmless. DB had petition_filed_date = CFC opinion date (wrong; 92-vv case).","is_death":0,"date_of_death":null,"petition_filed_date":"1995-07-18","case_summary":"Patricia Lynn Johnson, born approximately 1955, received a rubella vaccine on December 14, 1989, at approximately age 34. She filed a petition under the National Childhood Vaccine Injury Compensation Program alleging that the vaccine caused her to develop arthropathy and fibromyalgia syndrome (FMS). Her case was part of the Omnibus Proceeding established to resolve a large group of claims alleging rubella vaccine-caused arthritis and arthropathy. Under the Omnibus framework, each petitioner was required to satisfy a six-part causation test.\n\nThe special master denied the petition. Among the special master's findings: petitioner's clinical presentation was the reverse of the pattern typical for rubella vaccine-induced arthropathy; and petitioner's fibromyalgia symptoms appeared to have preceded rather than followed the arthropathic symptoms attributed to the vaccine. The special master also invoked the statutory exclusion at 42 U.S.C. § 300aa-13(a)(2)(A), which bars compensation when \"the illness, disability, injury, or condition\" was caused by \"factors unrelated to the administration of the vaccine\" — including, in the special master's view, a condition of unknown etiology (such as fibromyalgia). Petitioner filed a motion for review.\n\nSenior Judge Gibson, writing for the Court of Federal Claims on July 18, 1995, affirmed the special master's decision in all respects. The court held that the special master applied the correct legal standard — the preponderance of the evidence standard under § 300aa-13(a)(1)(A), not any more demanding \"most likely cause\" test. The court found that the § 300aa-13(a)(2)(A) idiopathic/unknown-etiology analysis was moot: petitioner had already failed to establish causation-in-fact under § 300aa-13(a)(1)(A), making the government's alternative § 13(a)(2)(A) argument legally unnecessary to reach. The court acknowledged that the special master had committed a minor evidentiary error in excluding reasoning (not just conclusions) from the reports of Dr. Tingle, a rubella arthritis expert whose reports were at issue in many Omnibus cases — but applied the harmless error doctrine, finding that even if those portions of Dr. Tingle's reports had been fully considered, the outcome would not have changed given the weight of the remaining record. The special master's factual findings were not arbitrary, capricious, or an abuse of discretion. The denial was affirmed.","is_minor_inferred":0,"is_pediatric_broad":0,"special_master":"George L. Hastings Jr.","petitioner_identifier_original":null,"caption_petitioner_name":null,"petitioner_attorney_name":null,"petitioner_attorney_firm":null,"petitioner_attorney_location":null,"adjudicator_name":null,"caption_people_backfilled_at":null,"attorney_canonical_keys":null,"firm_canonical_key":null,"package_title":"Johnson v. Secretary of Health & Human Services","canonical_url":"https://vicp-registry.org/case/USCOURTS-cofc-1_92-vv-00478","plain_text_url":"https://vicp-registry.org/case/USCOURTS-cofc-1_92-vv-00478.txt","json_url":"https://vicp-registry.org/case/USCOURTS-cofc-1_92-vv-00478.json","source_documents":[{"granule_id":"USCOURTS-cofc-1_92-vv-00478-cl6645532","title":"Johnson v. Secretary of Health & Human Services","docket_text":"lead-opinion","date_issued":"1995-07-18","pdf_url":"https://www.courtlistener.com/opinion/6762792/johnson-v-secretary-of-health-human-services/","pdf_bytes":null,"triage_decision":"keep","triage_reason":"recovered via CL opinion 6645532 (html_with_citations)","download_status":"ok","registry_pdf_url":"https://vicp-registry.org/pdf/USCOURTS-cofc-1_92-vv-00478/USCOURTS-cofc-1_92-vv-00478-cl6645532"}]}