Off-Table causation wins

Live · 13,358 cases in database · latest filing 2026-05-12

The citable precedent set for causation-in-fact. These are the reasoned decisions in which a Special Master found, under Althen v. HHS, that a vaccine more likely than not caused an injury that is not on the Vaccine Injury Table, or fell outside its onset window. Filter by condition and vaccine to find the decisions, Special Masters and experts behind a theory that has already succeeded.

Off-Table wins

168

reasoned decisions finding causation

Shown

after filters

Conditions

distinct categories

With named expert

petitioner expert identified in text

Off-Table causation wins by condition

Reasoned decisions where the petitioner proved causation without a Table presumption.

Decisions

Decided	Case	Vaccine	Condition	Special Master	Petitioner's expert(s)	Basis	Award
2026-05-13	Harvard Davis	Influenza	Guillain-Barré Syndrome	Mindy Michaels Roth	not identified	Off-Table	$586K
2026-03-25	Roy Romero	Influenza	Guillain-Barré Syndrome	Brian H. Corcoran	Akbari	Althen analysis (Table also discussed)	entitlement
2026-03-02	Carolann Sinclair	Pneumococcal	Guillain-Barré Syndrome	Thomas L. Gowen	John, Lawrence Steinman, John Hixson	Althen analysis (Table also discussed)	entitlement
2026-02-20	Nicholas Gillon	Tdap	Guillain-Barré Syndrome	Thomas L. Gowen	David, David M. Simpson	Off-Table	entitlement
2026-02-20	James G. Strouse	Hepatitis B	Guillain-Barré Syndrome	—	Lawrence Steinman	Off-Table	entitlement
2026-01-15	Ricardo Rodriguez	HPV	Guillain-Barré Syndrome	Jennifer A. Shah	David M. Simpson	Althen analysis (Table also discussed)	entitlement
2025-12-30	Donna Faye McKenney	Pneumococcal	Guillain-Barré Syndrome	Thomas L. Gowen	David, Axelrod, Kevin Jamison	Off-Table	entitlement
2025-11-19	Eric Simmons	HPV	Guillain-Barré Syndrome	Jennifer A. Shah	Norman Latov	Althen analysis (Table also discussed)	entitlement
2025-09-23	Doris DiPonziano	Pneumococcal	Guillain-Barré Syndrome	Thomas L. Gowen	Robert Knobler, Robert Hyzy	Althen analysis (Table also discussed)	$250K
2025-07-08	Noah E. Musick	Pneumococcal	Guillain-Barré Syndrome	Thomas L. Gowen	Lawrence Steinman	Althen analysis (Table also discussed)	entitlement
2025-03-19	S.R.	Influenza	Guillain-Barré Syndrome	Mindy Michaels Roth	David Simpson	Althen analysis (Table also discussed)	entitlement
2024-10-29	Amy Morris	Td/Tetanus	Guillain-Barré Syndrome	Thomas L. Gowen	Frederick Nahm	Althen analysis	entitlement
2024-07-29	Jeffrey Cooper	Pneumococcal	Guillain-Barré Syndrome	Daniel T. Horner	not identified	Off-Table	$181K
2024-07-08	Dianne Byrd	Pneumococcal	Guillain-Barré Syndrome	Thomas L. Gowen	David Axelrod	Althen analysis (Table also discussed)	entitlement
2024-06-21	Ala Mohamad	Tdap	Guillain-Barré Syndrome	Christian J. Moran	Shafrir	Althen analysis (Table also discussed)	$919K
2024-04-26	Donald D. Meyer	Pneumococcal	Guillain-Barré Syndrome	Nora Beth Dorsey	not identified	Off-Table	$454K
2024-01-08	J. G.	Hepatitis A	Guillain-Barré Syndrome	Nora Beth Dorsey	not identified	Off-Table	$189K
2023-07-13	Donna Osso	Hepatitis B	Guillain-Barré Syndrome	Nora Beth Dorsey	not identified	Off-Table	entitlement
2023-05-15	Shawn’Quavious A’drez Hinton	Influenza	Guillain-Barré Syndrome	Nora Beth Dorsey	not identified	Althen analysis	$178K
2022-09-22	Jennifer Gross	Pneumococcal	Guillain-Barré Syndrome	Nora Beth Dorsey	not identified	Off-Table	entitlement
2022-05-03	Carolyn Pierson	Pneumococcal	Guillain-Barré Syndrome	Daniel T. Horner	not identified	Off-Table	$155K
2015-06-15	Sherry Salmins	HPV	Guillain-Barré Syndrome	Nora Beth Dorsey	not identified	Off-Table	$1.4M
2014-06-12	Fred Brock	Influenza	Guillain-Barré Syndrome	Thomas L. Gowen	not identified	Off-Table	—
2014-05-13	Cassandra Burchett	HPV	Guillain-Barré Syndrome	Nora Beth Dorsey	Allan E. Rubenstein	Off-Table	—
2011-06-24	Stacey Heinzelman	Influenza	Guillain-Barré Syndrome	—	Marcel Kinsbourne	Althen analysis (Table also discussed)	—
2005-08-31	Ryan Kelley	Td/Tetanus	Guillain-Barré Syndrome	—	not identified	Off-Table	—

Selection rule. A case is listed when a Special Master issued a reasoned decision in the petitioner's favour and either the extracted theory of causation is Off-Table, or the decision text applies the Althen test. Where the text also discusses a Table injury the Basis column says so; some of those are alternative holdings or Table claims with an Althen fallback, so check the decision. SIRVA rulings are included only when explicitly Off-Table (pre-2017 shoulder claims). Expert names are read from the decision text where the opinion attributes them to the petitioner; absence means the text did not name one in a recognisable form, not that none testified. Verify against the linked decision before citing.

How off-Table causation is decided

When an injury is not on the Vaccine Injury Table, or falls outside its onset window, the petitioner must prove causation under the three-part test from Althen v. Secretary of HHS (Fed. Cir. 2005): a medical theory connecting the vaccine to the injury, a logical sequence of cause and effect in this petitioner's case, and a medically appropriate interval between vaccination and onset. The standard is preponderance of the evidence, and the Special Master weighs competing expert reports rather than requiring epidemiological proof.

That makes prior reasoned decisions the working precedent of the program. A theory accepted for a given vaccine and condition is easier to carry the second time, and the experts who carried it are the ones later petitioners retain. Decisions are not formally binding on other Special Masters, but they are cited constantly, and the Court of Federal Claims and the Federal Circuit review them for arbitrariness rather than re-trying the facts.