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
2026-01-15	Ricardo Rodriguez	HPV	Guillain-Barré Syndrome	Jennifer A. Shah	David M. Simpson	Althen analysis (Table also discussed)	entitlement
2025-11-19	Eric Simmons	HPV	Guillain-Barré Syndrome	Jennifer A. Shah	Norman Latov	Althen analysis (Table also discussed)	entitlement
2025-09-02	Theo Rogan	HPV	Other / multiple	Nora Beth Dorsey	M. Eric Gershwin, Jill, M. Eric	Off-Table	entitlement
2023-08-21	Trey Cobb	HPV	Narcolepsy / cataplexy	Katherine E. Oler	Lawrence Steinman	Althen analysis	entitlement
2023-06-20	Victoria Mager	HPV	Death	Christian J. Moran	Shafrir	Off-Table	$366K
2022-04-28	A.C.W.	HPV	Transverse myelitis	Thomas L. Gowen	not identified	Off-Table	$659K
2021-06-23	Matthew Jimenez	HPV	Other / multiple	Nora Beth Dorsey	not identified	Althen analysis (Table also discussed)	entitlement
2018-02-26	Emily Tarsell, as the Executrix of the Estate of Christina Tarsell	HPV	Death	Christian J. Moran	not identified	Althen analysis	$310K
2017-09-22	R.B.	HPV	Encephalitis / encephalopathy	Brian H. Corcoran	not identified	Off-Table	$195K
2016-08-30	Megan Morgan	HPV	Other / multiple	Thomas L. Gowen	not identified	Off-Table	$800K
2016-05-25	Megan L. Godfrey	HPV	Other / multiple	Denise K. Vowell	Michael McCabe	Off-Table	$142K
2016-05-12	Michayla Waterman	HPV	Other / multiple	Lisa D. Hamilton-Fieldman	not identified	Off-Table	$166K
2015-12-18	Donna Ramsay	HPV	Other / multiple	Lisa D. Hamilton-Fieldman	Michael McCabe	Althen analysis (Table also discussed)	—
2015-06-15	Sherry Salmins	HPV	Guillain-Barré Syndrome	Nora Beth Dorsey	not identified	Off-Table	$1.4M
2015-05-22	Rachel McCulloch	HPV	Encephalitis / encephalopathy	Thomas L. Gowen	not identified	Off-Table	$1.4M
2014-05-13	Cassandra Burchett	HPV	Guillain-Barré Syndrome	Nora Beth Dorsey	Allan E. Rubenstein	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.