Ampofo-Addo v. Secretary of Health and Human Services

CourtUnited States Court of Federal Claims
DecidedJanuary 20, 2026
Docket21-1231V
StatusUnpublished

This text of Ampofo-Addo v. Secretary of Health and Human Services (Ampofo-Addo v. Secretary of Health and Human Services) is published on Counsel Stack Legal Research, covering United States Court of Federal Claims primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Ampofo-Addo v. Secretary of Health and Human Services, (uscfc 2026).

Opinion

In the United States Court of Federal Claims OFFICE OF SPECIAL MASTERS No. 21-1231V

************************* * ADWOA AMPOFO-ADDO, * * Petitioner, * Filed: December 17, 2025 * v. * * SECRETARY OF HEALTH AND * HUMAN SERVICES, * * Respondent. * * *************************

Maximillian J. Muller, Muller Brazil, LLP, Dresher, PA, for Petitioner.

Rachelle Bishop, U.S. Department of Justice, Washington, DC, for Respondent.

DECISION GRANTING IN PART MOTION FOR FINAL AWARD OF ATTORNEY’S FEES AND COSTS 1

On April 16, 2021, Adwoa Ampofo-Addo filed a petition for compensation under the National Vaccine Injury Compensation Program (the “Vaccine Program”). 2 Petitioner alleged that her receipt of a tetanus, diphtheria, and acellular pertussis vaccine on April 17, 2018, as well as measles-mumps- rubella and varicella vaccines administered on April 24, 2018, caused her to suffer myelin oligodendrocyte glycoprotein antibody-associated disease (“MOGAD”), and/or MOG-positive acute disseminated encephalomyelitis. See Amended Petition, dated July 31, 2024 (ECF No. 41). A two-day hearing was held on November 12, 2024, and I subsequently issued a decision denying entitlement. Decision, dated July 31, 2025 (ECF No. 69).

1 This Decision will be posted on the United States Court of Federal Claims’ website in accordance with the E- Government Act of 2002, 44 U.S.C. § 3501 (2012). This means the Decision will be available to anyone with access to the internet. As provided by 42 U.S.C. § 300aa-12(d)(4)(B), however, the parties may object to the published Decision’s inclusion of certain kinds of confidential information. Specifically, under Vaccine Rule 18(b), each party has fourteen (14) days within which to request redaction “of any information furnished by that party: (1) that is a trade secret or commercial or financial in substance and is privileged or confidential; or (2) that includes medical files or similar files, the disclosure of which would constitute a clearly unwarranted invasion of privacy.” Vaccine Rule 18(b). Otherwise, the entire Decision will be available to the public in its current form. Id. 2 The Vaccine Program comprises Part 2 of the National Childhood Vaccine Injury Act of 1986, Pub. L. No. 99-660, 100 Stat. 3758, codified as amended, 42 U.S.C. §§ 300aa-10 through 34 (2012) [hereinafter “The Program” or “Program”]. Individual section references hereafter will be to Section 300aa of the Act. Petitioner previously obtained an interim award of fees and costs after the hearing, although I deferred ruling on costs related to her expert, Omid Akbari, Ph.D. Motion for Interim Attorney’s Fees and Costs, dated Dec. 27, 2024 (ECF No. 60) (“Interim Fees Mot.”); Interim Fees Decision, dated Feb. 27, 2025 (ECF No. 65). Petitioner has now sought her final award of fees and costs, seeking compensation for expenses incurred since filing her Interim Fee Request plus Dr. Akbari’s total fees and costs for his work on the matter. Final Application for Attorney’s Fees and Costs, dated Oct. 21, 2025 (ECF No. 73) (“Final Fees Mot.”). In total, Petitioner is seeking $66,211.00, comprised of $4,336.00 in attorney’s fees and $61,875.00 in costs.

Respondent reacted to the fees request on November 4, 2025. See Response, dated Nov. 4, 2025 (ECF No. 74) (“Resp.”). Respondent defers to my discretion as to whether the statutory requirements for an award of attorney’s fees and costs are met in this case, and if so, the calculation of the amount to be awarded. Resp. at 2, 9. Petitioners elected to not file a Reply.

For the reasons set forth below, I hereby GRANT IN PART Petitioners’ motion in part, awarding fees and costs in the total amount of $49,336.00.

ANALYSIS

I. Petitioner’s Claim had Reasonable Basis

Although the Vaccine Act only guarantees a fees award to successful petitioners, a special master may also award fees and costs in an unsuccessful case if: (1) the “petition was brought in good faith”; and (2) “there was a reasonable basis for the claim for which the petition was brought.” Section 15(e)(1). I have in prior decisions set forth at length the criteria to be applied when determining if a claim possessed “reasonable basis” sufficient for a fees award. See, e.g., Sterling v. Sec’y of Health & Hum. Servs., No. 16-551V, 2020 WL 549443, at *4 (Fed. Cl. Spec. Mstr. Jan. 3, 2020). Importantly, establishing reasonable basis does not automatically entitle an unsuccessful claimant to fees, but is instead a threshold obligation; fees can still thereafter be limited, if unreasonable, or even denied entirely.

A claim’s reasonable basis must be demonstrated through some objective evidentiary showing. Cottingham v. Sec’y of Health & Hum. Servs., 971 F.3d 1337, 1344 (Fed. Cir. 2020) (citing Simmons v. Sec’y of Health & Hum. Servs., 875 F.3d 632, 635 (Fed. Cir. 2017)). This objective inquiry is focused on the claim—counsel’s conduct is irrelevant (although it may bulwark good faith). Simmons, 875 F.3d at 635. In addition, reasonable basis inquiries are not static—they evaluate not only what was known at the time the petition was filed, but also take into account what is learned about the evidentiary support for the claim as the matter progresses. Perreira v. Sec’y of Health & Hum. Servs., 33 F.3d 1375, 1377 (Fed. Cir. 1994) (upholding the

2 finding that a reasonable basis for petitioners’ claims ceased to exist once they had reviewed their expert's opinion, which consisted entirely of unsupported speculation). As a result, a claim can “lose” reasonable basis over time.

The standard for finding the existence of reasonable basis is lesser (and thus inherently easier to satisfy) than the preponderant standard applied when assessing entitlement, as cases that fail can still have sufficient objective grounding for a fees award. Braun v. Sec’y of Health & Hum. Servs., 144 Fed. Cl. 72, 77 (2019). The Court of Federal Claims has affirmed that “[r]easonable basis is a standard that petitioners, at least generally, meet by submitting evidence.” Chuisano v. Sec’y of Health & Hum. Servs., 116 Fed. Cl. 276, 287 (Fed. Cl. 2014) (internal quotations omitted) (affirming special master). The factual basis and medical support for the claim is among the evidence that should be considered. Carter v. Sec’y of Health & Hum. Servs., 132 Fed. Cl. 372, 378 (Fed. Cl. 2017). Under the Vaccine Act, special masters have “maximum discretion” in applying the reasonable basis standard. See, e.g., Silva v. Sec’y of Health & Hum. Servs., 108 Fed. Cl. 401, 401–02 (Fed. Cl. 2012).

Although Petitioner’s claim was ultimately unsuccessful, I find that there was sufficient objective basis to entitle her to a fees and costs award. There was record evidence that Petitioner experienced a variety of symptoms after the relevant vaccines. In addition, theories that an individual’s MOGAD could have been vaccine-caused are very much legitimate; the Program certainly has not at this point reached a consensus on the validity of this particular vaccine injury. I also note that I previously awarded interim fees based upon the claim, and nothing from a fact standpoint changed in the matter as it proceeded that would justify a finding that reasonable basis ceased to exist once the matter was fully resolved.

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