Brundage v. Becerra

District Court, District of Columbia·Decided September 29, 2025·No. Civil Action No. 2025-0119·Published

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

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,

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, and relief under the All Writs Act, 28 U.S.C. § 1651.

On May 5, 2025, the Secretary moved to dismiss under Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6). Def.’s Mot. Dismiss, ECF No. 9. That motion is fully briefed and ripe for review. See Pl.’s Resp., ECF No. 10; Def.’s Reply, ECF No. 12; Pl.’s Sur-Reply, ECF No. 15.

2 The Court notes that there is more than one vaccine for COVID–19. See Kathy Katella, Comparing the COVID-19 Vaccines: How Are They Different?, Yale Medicine (May 20, 2025), https://www.yalemedicine.org/news/covid-19-vaccine-comparison [https://perma.cc/65AZ- U7HA]. The Complaint does not specify which COVID–19 vaccine or vaccines the CDC recommended. Because the Parties do not differentiate between the COVID–19 vaccines, this Court assumes that any differences between those vaccines are not relevant to Mr. Brundage’s claims.

LEGAL STANDARD

“When a defendant brings a Rule 12(b)(1) motion to dismiss, the plaintiff must demonstrate that the court indeed has subject-matter jurisdiction to hear his claims.” Hill v. U.S. Dep’t of the Interior, 699 F. Supp. 3d 1, 12 (D.D.C. 2023) (first citing Lujan v. Defs. of Wildlife, 504 U.S. 555, 561 (1992); and then citing U.S. Ecology, Inc. v. U.S. Dep’t of Interior, 231 F.3d 20, 24 (D.C. Cir. 2000)). In reviewing a motion to dismiss for lack of jurisdiction under Federal Rule of Civil Procedure 12(b)(1), courts “construe the complaint liberally, granting plaintiff the benefit of all inferences that can be derived from the facts alleged.” Thomas v. Principi, 394 F.3d 970, 972 (D.C. Cir. 2005) (internal quotation marks and citation omitted).

DISCUSSION

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