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
2025-12-22	Guy Irwin	Influenza	Encephalitis / encephalopathy	Thomas L. Gowen	not identified	Off-Table	$426K
2025-10-02	H.H.	DTaP	Encephalitis / encephalopathy	Katherine E. Oler	Warren Marks	Off-Table	$2.9M
2025-09-02	T.B.D.	DTaP	Encephalitis / encephalopathy	Nora Beth Dorsey	Anthony Chang, Perry Lubens, Anthony	Althen analysis (Table also discussed)	entitlement
2025-03-05	E.M.	Influenza	Encephalitis / encephalopathy	Daniel T. Horner	Jeffrey M. Silverman	Althen analysis (Table also discussed)	entitlement
2025-01-24	Lindy Sells	MMR	Encephalitis / encephalopathy	Nora Beth Dorsey	Carlo Tornatore, Carlos	Off-Table	entitlement
2024-08-08	K.M.	Hib	Encephalitis / encephalopathy	Nora Beth Dorsey	Robert Shuman, Lawrence, Robert	Althen analysis (Table also discussed)	—
2023-12-21	Robert Joseph Gardner	Influenza	Encephalitis / encephalopathy	Thomas L. Gowen	Steinman	Off-Table	entitlement
2023-08-02	K.N.	Tdap	Encephalitis / encephalopathy	Brian H. Corcoran	not identified	Off-Table	$194K
2023-06-12	Hans Hofer	Influenza	Encephalitis / encephalopathy	Thomas L. Gowen	not identified	Off-Table	entitlement
2021-07-15	Radhika Agarwal	Tdap	Encephalitis / encephalopathy	Thomas L. Gowen	not identified	Off-Table	$2.0M
2019-05-21	Carmen Moreno Lozano	Tdap	Encephalitis / encephalopathy	Brian H. Corcoran	Norman Latov	Off-Table	$1.3M
2017-09-22	R.B.	HPV	Encephalitis / encephalopathy	Brian H. Corcoran	not identified	Off-Table	$195K
2017-04-25	Lisa Turner	Hepatitis B	Encephalitis / encephalopathy	Thomas L. Gowen	not identified	Off-Table	$1.0M
2015-05-22	Rachel McCulloch	HPV	Encephalitis / encephalopathy	Thomas L. Gowen	not identified	Off-Table	$1.4M
2015-03-23	Justin W. Gerhardt	multiple	Encephalitis / encephalopathy	Brian H. Corcoran	not identified	Off-Table	$2.3M

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.