FELIX v. SECRETARY OF HEALTH AND HUMAN SERVICES

CourtUnited States Court of Federal Claims
DecidedFebruary 21, 2025
Docket21-1728V
StatusUnpublished

This text of FELIX v. SECRETARY OF HEALTH AND HUMAN SERVICES (FELIX 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.

Bluebook
FELIX v. SECRETARY OF HEALTH AND HUMAN SERVICES, (uscfc 2025).

Opinion

In the United States Court of Federal Claims OFFICE OF SPECIAL MASTERS No. 21-1728V

STEPHANIE FELIX and ASHTON Chief Special Master Corcoran FELIX, on behalf of E.A.F.,

Petitioners, Filed: January 17, 2025 v.

SECRETARY OF HEALTH AND HUMAN SERVICES,

Respondent.

John Leonard Shipley, Davis, CA, for Petitioners.

Mallori Browne Openchowski, U.S. Department of Justice, Washington, DC, for Respondent.

DECISION ON ATTORNEYS’ FEES AND COSTS1

On August 19, 2021, Stephanie and Ashton Felix, acting on behalf of their minor child E.A.F., filed a Petition under the National Vaccine Injury Compensation Program, 42 U.S.C. § 300aa-10, et seq.2 (the “Vaccine Program”). Petitioners alleged that following his receipt of an August 6, 2018, measles-mumps-rubella (“MMR”) vaccine, E.A.F. suffered from immune thrombocytopenic purpura (“ITP”), with residual effects and complications lasting for more than six months. Petition (ECF No. 1); see also Amended Petition filed May 13, 2022 (ECF No. 18); 42 C.F.R. §§ 100.3(a)(V)(A) and (c)(7) (listing of MMR/ITP on the Vaccine Injury Table).

1 Because this unpublished decision contains a reasoned explanation for the action in this case, I am

required to post it on the United States Court of Federal Claims' website in accordance with the E- Government Act of 2002. 44 U.S.C. § 3501 note (2012) (Federal Management and Promotion of Electronic Government Services). This means the decision will be available to anyone with access to the internet. In accordance with Vaccine Rule 18(b), petitioner has 14 days to identify and move to redact medical or other information, the disclosure of which would constitute an unwarranted invasion of privacy. If, upon review, I agree that the identified material fits within this definition, I will redact such material from public access. 2 National Childhood Vaccine Injury Act of 1986, Pub. L. No. 99-660, 100 Stat. 3755. Hereinafter, for ease

of citation, all section references to the Vaccine Act will be to the pertinent subparagraph of 42 U.S.C. § 300aa (2018). In May 2022, the case was assigned to the Special Processing Unit of the Office of Special Masters, since it alleged a Table injury. But there was a threshold issue of whether the injury was sufficiently severe, under the meaning of Section 11(c)(1)(D)(i), to be eligible for the Program. After receiving Petitioners’ additional fact evidence and both parties’ briefing (completed in October 2023), I concluded that Petitioners had not made that showing, requiring dismissal of their claim. Decision granting Respondent’s Motion to Dismiss dated Apr. 29, 2024 (ECF No. 42) (hereinafter “Dismissal Decision”). The Court of Federal Claims sustained that finding. Opinion and Order dated July 30, 2024 (ECF No. 47) (hereinafter “CFC Opinion”).

On August 14, 2024, Petitioners submitted their (first and final) request for attorneys’ fees and costs. ECF No. 50. Petitioners represented that they did not incur any out-of-pocket expenses. ECF No. 50-3. On August 19, 2024, Respondent deferred to the Court’s determination as to whether the case meets the statutory requirements for an award of attorneys’ fees and costs, and if so, the appropriate amount to be awarded. Response (ECF No. 51) at 2, 4. Petitioners have not filed a reply. For the reasons set forth below, Petitioners’ motion is granted.

Petitioners’ Claim Had Reasonable Basis

Motivated by a desire to ensure that petitioners have adequate assistance from counsel when pursuing their claims, Congress determined that attorney’s fees and costs may be awarded even in some unsuccessful claims. H.R. REP. NO. 99-908, at 22 reprinted in 1986 U.S.C.C.A.N. 6344, 6363; see also Sebelius v. Cloer, 133 S. Ct. 1886, 1895 (2013) (discussing this goal when determining that attorneys’ fees and costs may be awarded even when the petition was untimely filed). This is consistent with the fact that “the Vaccine Program employs a liberal fee-shifting scheme.” Davis v. Sec’y of Health & Human Servs., 105 Fed. Cl. 627, 634 (2012). Indeed, it may be the only federal fee- shifting statute that permits unsuccessful litigants to recover fees and costs.

However, Congress did not intend that every losing petition be automatically entitled to attorney’s fees. Perreira v. Sec’y of Health & Human Servs., 33 F.3d 1375, 1377 (Fed. Cir. 1994). The special master or court may award attorney’s fees and costs to an unsuccessful claimant only if “the petition was brought in good faith and there was a reasonable basis for the claim for which the petition was brought.” Section 15(e)(1). Reasonable basis is a prerequisite to a fee award for unsuccessful cases – but establishing it does not automatically require an award, as special masters are still empowered by the Act to deny or limit fees. James-Cornelius on behalf of E. J. v. Sec'y of Health & Human Servs., 984 F.3d 1374, 1379 (Fed. Cir. 2021) (“even when these two

2 requirements are satisfied, a special master retains discretion to grant or deny attorneys’ fees”).

As the Federal Circuit has explained, whether a discretionary fees award is appropriate involves two distinct inquiries, but only reasonable basis is at issue herein.3 Reasonable basis is deemed “an objective test, satisfied through objective evidence.” Cottingham v. Sec’y of Health & Human Servs., 971 F.3d 1337, 1344 (Fed. Cir. 2020) (“Cottingham I”). The reasonable basis requirement looks “not at the likelihood of success [of a claim] but more to the feasibility of the claim.” Turner, 2007 WL 4410030, at *6 (quoting Di Roma v. Sec’y of Health & Human Servs., No. 90-3277V, 1993 WL 496981, at *1 (Fed. Cl. Spec. Mstr. Nov. 18, 1993)). The Federal Circuit recently explained “that a reasonable basis analysis is limited to objective evidence, and that subjective considerations, such as counsel’s subjective views on the adequacy of a complaint, do not factor into a reasonable basis determination.” James-Cornelius, 984 F.3d at 1379.

Although easier to meet than the preponderant standard required for compensation, “courts have struggled with the nature and quantum of evidence necessary to establish a reasonable basis.” Wirtshafter v. Sec’y of Health & Human Servs., 155 Fed. Cl. 665, 671 (Fed. Cl. 2021). “[I]t is generally accepted that ‘a petitioner must furnish some evidence in support of the claim.’” Id. Citing the prima facie elements of a successful claim described in Section 11(c)(1), the Federal Circuit recently instructed that the level of objective evidence sufficient for a special master to find reasonable basis should be “more than a mere scintilla but less than a preponderance of proof.” Cottingham I, 971 F.3d at 1345-46. “This formulation does not appear to define reasonable basis so much as set its outer bounds.” Cottingham v. Sec’y of Health & Human Servs., 159 Fed. Cl. 328, 333, (Fed. Cl. 2022), aff’d without op., 2023 WL 754047 (Fed. Cir. Nov. 14, 2023) (“Cottingham II”). “[T]he Federal Circuit’s statement that a special master ‘could’ find reasonable basis based upon more than a mere scintilla does not mandate such a finding.” Cottingham II, 159 Fed. Cl. at 333 (citing Cottingham I, 971 F.3d at 1346).

Furthermore, reasonable basis is not a static inquiry.

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Related

Hensley v. Eckerhart
461 U.S. 424 (Supreme Court, 1983)
Sebelius v. Cloer
133 S. Ct. 1886 (Supreme Court, 2013)
Chuisano v. Secretary of Health and Human Services
116 Fed. Cl. 276 (Federal Claims, 2014)
Simmons v. Secretary of Health & Human Services
875 F.3d 632 (Federal Circuit, 2017)
Savin v. Secretary of Health & Human Services
85 Fed. Cl. 313 (Federal Claims, 2008)
Broekelschen v. Secretary of Health & Human Services
102 Fed. Cl. 719 (Federal Claims, 2011)
Davis v. Secretary of Health & Human Services
105 Fed. Cl. 627 (Federal Claims, 2012)

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