Brundage v. Becerra

CourtDistrict Court, District of Columbia
DecidedSeptember 29, 2025
DocketCivil Action No. 2025-0119
StatusPublished

This text of Brundage v. Becerra (Brundage v. Becerra) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Brundage v. Becerra, (D.D.C. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

PAUL BRUNDAGE,

Plaintiff,

v. Civil Action No. 25 - 119 (SLS) Judge Sparkle L. Sooknanan ROBERT F. KENNEDY, JR., Secretary, United States Department of Health and Human Services, 1

Defendant.

MEMORANDUM OPINION

Paul Brundage alleges that he suffered a blood clotting disorder as a result of receiving a

vaccine for COVID–19. He wants to seek compensation for this injury under the National Vaccine

Injury Compensation Program (VICP), a federal program established to compensate individuals

injured by vaccines. But to seek compensation for an injury allegedly caused by the COVID–19

vaccine, that vaccine must first be added to the VICP’s Vaccine Injury Table. Mr. Brundage

contends that the Secretary of Health and Human Services has a duty to add the COVID–19

vaccine to the Table, and that the Secretary has failed to do so. Accordingly, Mr. Brundage brought

this lawsuit, asking the Court to order the Secretary to add the COVID–19 vaccine to the Vaccine

Injury Table. The Secretary has moved to dismiss under Federal Rules of Civil Procedure 12(b)(1)

and 12(b)(6). Because the Court lacks subject matter jurisdiction, the Court grants the Secretary’s

motion under Rule 12(b)(1) and dismisses the case without prejudice.

1 The current Secretary is substituted for his predecessor pursuant to Fed. R. Civ. P. 25(d). BACKGROUND

A. Statutory Background

Congress promulgated the National Childhood Vaccine Injury Act of 1986 (NCVIA), Pub.

L. No. 99–660, 100 Stat. 3755 (codified as amended at 42 U.S.C. § 300aa–1 et seq.), “[t]o stabilize

the vaccine market and facilitate compensation” for individuals injured by vaccines. Bruesewitz v.

Wyeth LLC, 562 U.S. 223, 228 (2011). To achieve these goals, the NCVIA has two major features:

first, it contains “significant tort-liability protections for vaccine manufacturers,” id. at 229, and

second, it created the VICP, Booth v. Bowser, 597 F. Supp. 3d 1, 8 (D.D.C. 2022). The VICP is a

“no-fault compensation program ‘designed to work faster and with greater ease than the civil tort

system.’” Bruesewitz, 562 U.S. at 228 (quoting Shalala v. Whitecotton, 514 U.S. 268, 269 (1995)).

Under the VICP, an individual who claims a vaccine injury may file a petition against the

Secretary of Health and Human Services in the United States Court of Federal Claims. 42 U.S.C.

§ 300aa–11(a)(1). The petition is then assigned to a special master, who adjudicates it. Id.

§ 300aa–12(d). Either party may object to the special master’s decision in the Court of Federal

Claims. Id. § 300aa–12(e)(1). After the Court of Federal Claims enters a final judgment, the

petitioner can choose “to accept the court’s judgment and forgo a traditional tort suit for damages,

or to reject the judgment and seek tort relief from the vaccine manufacturer.” Bruesewitz, 562 U.S.

at 228 (citing 42 U.S.C. § 300aa–21(a)).

But before a vaccine can give rise to a VICP claim, two preconditions must be met. First,

that vaccine must be added to the so-called “Vaccine Injury Table.” See 42 U.S.C. § 300aa–14(a);

see also Scanlon v. Sec’y of Health & Hum. Servs., 114 Fed. Cl. 135, 141 (Fed. Cl. 2013) (“If a

vaccine is not . . . listed on the Table, any injury caused by its administration is not compensable,

and the injured party has no cognizable claim under the [NCVIA].”). The Table lists vaccines and

compensable injuries caused by those vaccines. See 42 C.F.R. § 100.3(a). Congress has itself

2 enumerated some vaccines for inclusion in the Table. See 42 U.S.C. § 300aa–14(a). And whenever

the Centers for Disease Control and Prevention (CDC) “recommends a vaccine to the Secretary

[of Health and Human Services] for routine administration to children” or “for routine

administration in pregnant women,” the Secretary “shall, within 2 years of such recommendation,

amend the Vaccine Injury Table” to add that vaccine. Id. § 300aa–14(e); see also id.

§ 300aa–14(c)(3) (providing that the Secretary generally “may add to, or delete from, the list of

injuries, disabilities, illnesses, conditions, and deaths for which compensation may be provided”).

Second, any putative addition to the Vaccine Injury Table following a CDC

recommendation takes effect only “upon the effective date of a tax enacted to provide funds for

compensation paid with respect to the vaccine to be added.” Omnibus Budget Reconciliation Act

of 1993, Pub. L. No. 103–66, § 13632(a)(3), 107 Stat. 312, 646 (1993) (codified at 42 U.S.C.

§ 300aa–14(e) note). The funds generated by that tax pay for successful VICP claims. Bruesewitz,

562 U.S. at 229.

B. Factual & Procedural Background

The Court draws the facts, accepted as true, from the Plaintiff’s Complaint. Wright v.

Eugene & Agnes E. Meyer Found., 68 F.4th 612, 619 (D.C. Cir. 2023).

Mr. Brundage “suffered an adverse reaction” to a COVID–19 vaccination “that left him

with a severe blood clotting disorder.” Compl. ¶ 1, ECF No. 1. He believes that he should now be

eligible to bring a compensation claim under the VICP. Compl. ¶ 2. According to the Complaint,

3 the CDC (on a date the Complaint does not specify) recommended the COVID–19 vaccine 2 for

routine administration to children, and “[s]ignificantly more than 2 years has passed” since then.

Compl. ¶ 14. Yet the Secretary of Health and Human Services has not added the COVID–19

vaccine to the Vaccine Injury Table. Compl. ¶ 16.

On November 15, 2024, Mr. Brundage sent a notice to the Secretary that the Secretary had

failed to meet his obligations under the NCVIA, and that Mr. Brundage intended to bring a lawsuit.

Compl. ¶¶ 17–18; see 42 U.S.C. § 300aa–31(b) (“No action may be commenced under [the

NCVIA] before the date which is 60 days after the person bringing the action has given written

notice of intent to commence such action to the Secretary.”). On January 16, 2025, Mr. Brundage

filed a Complaint in this Court. The Complaint alleges that the Secretary has failed to add the

COVID–19 vaccine to the Vaccine Injury Table as required by the NCVIA. Compl. ¶¶ 21–24. The

Complaint brings a claim under the NCVIA, see 42 U.S.C. § 300aa–31(a) (“[A]ny person may

commence in a district court of the United States a civil action . . . where there is alleged a failure

of the Secretary to perform any act or duty under this part.”), as well as claims for mandamus

under 28 U.S.C. § 1361

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