Beckwith v. Secretary of Health and Human Services

CourtUnited States Court of Federal Claims
DecidedMarch 9, 2026
Docket21-1660V
StatusPublished

This text of Beckwith v. Secretary of Health and Human Services (Beckwith 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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Beckwith v. Secretary of Health and Human Services, (uscfc 2026).

Opinion

In the United States Court of Federal Claims

DEBORAH BECKWITH, Petitioner, v. No. 21-vv-1660 (Filed Under Seal: February 20, 2026 SECRETARY OF HEALTH AND HUMAN Reissued for Publication: March 9, 2026)1 SERVICES, Respondent.

David John Carney, Green & Shafle LLC, Philadelphia, PA, for Petitioner. With him on the briefs were Grant Douglas Godfrey, Mctlaw, Washington, DC, and Jennifer Anne Gore Maglio, Maglio Christopher & Toale, P.A., Sarasota, FL. Parisa Tabassian, Torts Branch, Civil Division, United States Department of Justice, Washington, DC, for Respondent. With her on the briefs were Brett A. Shumate, Assistant Attorney General, C. Salvatore D’Alessio, Director, Heather L. Pearlman, Deputy Director, and Lara A. Englund, Assistant Director.

OPINION AND ORDER

Meriweather, Judge.

Petitioner, Ms. Deborah Beckwith (“Ms. Beckwith”), seeks review of Chief Special Master Corcoran’s Entitlement Decision (“Decision”), denying her entitlement to compensation pursuant to the National Childhood Vaccine Injury Act of 1986, 42 U.S.C. §§ 300aa-1–aa-34 (“Vaccine Act”). See Decision at 1, ECF No. 67. Ms. Beckwith filed a Petition under the Vaccine Program of the Vaccine Act, alleging the influenza (“flu”) vaccine caused her to suffer Guillain-Barré Syndrome (“GBS”)—a neurological disorder that can lead to numbness and muscle paralysis. See Petition at 1, ECF No. 1. The applicable regulations establish a presumption that the flu vaccine caused GBS if a petitioner proves that she developed GBS between three and forty-two days after receiving the flu vaccine. 42 C.F.R. § 100.3(a)(XIV)(D). Following a dispute about the number and timing of vaccines Ms. Beckwith received, the Chief Special Master determined Ms. Beckwith received one dose of flu vaccine at approximately 2:20 AM on September 24, 2019 and that the onset of her GBS occurred less than three days after vaccination. See Order Granting Second Motion for Reconsideration at 2–3, ECF No. 37.

1 Pursuant to Vaccine Rule 18(b)(1)–(2), (d), this Opinion was initially filed under seal on February 20, 2026, and the parties were afforded fourteen days to propose redactions. The parties did not propose any redactions and, accordingly, this Opinion is reissued in its original form for publication. Accordingly, the Chief Special Master concluded he could not presume causation and Ms. Beckwith had to prove causation-in-fact. The Chief Special Master determined that Ms. Beckwith failed to prove causation-in-fact because she could not establish, by a preponderance of the evidence, “that her GBS developed within a medically-acceptable timeframe after receipt of the flu vaccine.” Decision at 21. He therefore denied her Petition. Id. at 2.

Ms. Beckwith now seeks review of the Chief Special Master’s Decision in this Court, alleging he committed errors of law and made arbitrary and capricious factual findings. See Pet’r’s Mot. for Review (“Mot.”), ECF No. 70; Pet’r’s Mem. of Law in Support of Pet’r’s Mot. for Review (“Mem.”), ECF No. 70-1; see also 42 U.S.C. § 300aa-12(e)(1). Ms. Beckwith claims the Chief Special Master: (1) erroneously limited the evidence she could use to prove that the vaccine caused her GBS by treating the timeframe of onset that would support a presumption of causation as a hard and fast rule with an overly narrow exception; (2) failed to properly consider Ms. Beckwith’s medical theory of causation when evaluating whether she demonstrated a proximate temporal relationship; (3) applied a heightened standard of proof to Ms. Beckwith’s evidence; and (4) arbitrarily and capriciously evaluated Ms. Beckwith’s evidence. Mem. at 1. Respondent, the Secretary of Health and Human Services (“the Secretary”), counters that Ms. Beckwith has not shown the Chief Special Master erred. Resp’t’s Resp. to Mot. for Review (“Resp.”) at 1, ECF No. 73.

Having reviewed the record, the parties’ legal filings,2 and the relevant law, the Court DENIES Ms. Beckwith’s Motion for Review and SUSTAINS the Chief Special Master’s Decision. The Chief Special Master did not commit an error of law, and Ms. Beckwith’s other assertions amount to mere disagreement with the Chief Special Master’s well-reasoned factual findings, which is not a basis for overturning his Decision. See Hines ex rel. Sevier v. Sec’y of Health & Hum. Servs., 940 F.2d 1518, 1527 (Fed. Cir. 1991).

BACKGROUND

I. Statutory Framework

The Vaccine Act, enacted in 1986, created the National Vaccine Injury Compensation Program, through which claimants can petition to receive compensation for vaccine-related injuries or death. See generally 42 U.S.C. § 300aa-10(a). The Act identifies two ways for a petitioner to establish causation and thus qualify for compensation. First, a petitioner may establish that she, after receiving a designated vaccine, suffered an injury listed on the Vaccine Injury Table within the requisite time-period—commonly called a “Table Injury,” see 42 C.F.R. § 100.3(a)—in which case causation is presumed. See 42 U.S.C. § 300aa-11(c)(1). Alternatively, if a petitioner claims entitlement for an injury not listed in the Vaccine Injury

2 The following filings are relevant to this Opinion: Petition, ECF No. 1; Mot., ECF No. 70; Mem., ECF No. 70-1; Resp., ECF No. 73. Throughout, page citations to documents in the record refer to the document’s original pagination, unless the page is designated with an asterisk (e.g., *1), in which case the reference is to the pagination assigned by PACER/ECF.

2 Table, i.e., an “Off-Table case,” the petitioner must instead prove that the vaccination was the cause-in-fact (“actual causation” or “causation-in-fact”) of the vaccinee’s asserted injury. See id. § 300aa-11(c)(1)(C)(ii)(I), (II). To prove causation-in-fact for an Off-Table case, a petitioner must by a preponderance of the evidence demonstrate: “(1) a medical theory causally connecting the vaccination and the injury; (2) a logical sequence of cause and effect showing that the vaccination was the reason for the injury; and (3) a showing of a proximate temporal relationship between vaccination and injury.” Althen v. Sec’y of Health & Hum. Servs., 418 F.3d 1274, 1278 (Fed. Cir. 2005). Those three elements are commonly referred to as the “Althen prongs.” A “failure to establish any one prong is dispositive.” Exum v. Sec’y of Health & Hum. Servs., 175 Fed. Cl. 681, 702 (2025).

II. Factual Background

The Chief Special Master summarized and evaluated Ms. Beckwith’s medical history over the relevant time period, both parties’ expert reports, the medical literature submitted, and the relevant legal standards. See generally Decision. The Chief Special Master reviewed all the medical records, the medical literature, and the expert reports submitted in this case, but only specifically discussed the records, literature, and reports relevant to his conclusion on the third Althen prong in his Decision. Id. at 4, 20.

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Beckwith v. Secretary of Health and Human Services, Counsel Stack Legal Research, https://law.counselstack.com/opinion/beckwith-v-secretary-of-health-and-human-services-uscfc-2026.