Pearson v. Secretary of Health and Human Services

CourtUnited States Court of Federal Claims
DecidedMay 28, 2025
Docket21-2027V
StatusUnpublished

This text of Pearson v. Secretary of Health and Human Services (Pearson 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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Pearson v. Secretary of Health and Human Services, (uscfc 2025).

Opinion

In the United States Court of Federal Claims OFFICE OF SPECIAL MASTERS No. 21-2027V UNPUBLISHED

DRUSILLA PEARSON, Chief Special Master Corcoran

Petitioner, Filed: April 25, 2025 v.

SECRETARY OF HEALTH AND HUMAN SERVICES,

Respondent.

Courtney Christine Jorgenson, Siri & Glimstad, LLP, Phoenix, AZ, for Petitioner.

Katherine Carr Esposito, U.S. Department of Justice, Washington, DC, for Respondent.

(I) FINDINGS OF FACT AND CONCLUSIONS OF LAW DISMISSING TABLE CLAIM AND (II) ORDER TO SHOW CAUSE 1

On October 15, 2021, Drusilla Pearson filed a petition for compensation under the National Vaccine Injury Compensation Program, 42 U.S.C. §300aa-10, et seq. 2 (the “Vaccine Act”). Petitioner alleges that she suffered a Table injury – shoulder injury related to vaccine administration (“SIRVA”) – as a result of an influenza (“flu”) vaccine she received on October 16, 2018. Petition, ECF No. 1 at 1, 3. The case was assigned to the Special Processing Unit of the Office of Special Masters (the “SPU”).

1 Because this ruling contains a reasoned explanation for the action taken in this case, it must be made publicly accessible and will be posted on the United States Court of Federal Claims' website, and/or at https://www.govinfo.gov/app/collection/uscourts/national/cofc, in accordance with the E-Government Act of 2002. 44 U.S.C. § 3501 note (2018) (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). For the reasons stated below, I conclude that Petitioner has not established by preponderant evidence that the onset of her shoulder pain likely occurred within 48 hours of vaccination, as required to establish a Table SIRVA claim. In addition, the evidence strongly is unsupportive of any causation-in-fact claim as well, and therefore Petitioner must Show Cause why the matter should not be dismissed in its entirety.

I. Relevant Procedural History

In September 2022, I observed that based upon my preliminary review of the records in this case, it appeared that Petitioner could not establish that she suffered shoulder pain within 48 hours of her vaccination – one of the four QAI requirements necessary to demonstrate a Table SIRVA claim. ECF No. 16 (citing Ex. 6 at 256; 42 C.F.R. § 100.3(c)(10)(ii)). Thereafter, Petitioner was provided time to supplement the record with additional evidence documenting the onset of her injury. Subsequent to filing additional medical records, and sworn statements from five witnesses, Petitioner filed a Brief Addressing Onset on May 16, 2023, and arguing that this Table element can be met. ECF No. 30. On June 15, 2023, Respondent filed his Rule 4(c) Report and Response to Petitioner’s Brief Regarding Onset. ECF No. 31. Respondent contends that Petitioner has failed to establish that she suffered shoulder pain within 48 hours of her vaccination, meaning she cannot prevail on a Table SIRVA. Id. at 13-18. Respondent further argues that Petitioner has failed to demonstrate an off-Table claim under the applicable legal standard and therefore her claim must be dismissed. Id. at 18-21. Finally, Respondent asserts that Petitioner has failed to demonstrate a reasonable basis for her claim, and states that he will challenge any request by Petitioner for fees and costs in this case. Id. at 20. On July 17, 2023, Petitioner filed a Reply brief. ECF No. 32. This matter is now ripe for adjudication.

II. Authority

Pursuant to Vaccine Act Section 13(a)(1)(A), a petitioner must prove, by a preponderance of the evidence, the matters required in the petition by Vaccine Act Section 11(c)(1). A special master must consider, but is not bound by, any diagnosis, conclusion, judgment, test result, report, or summary concerning the nature, causation, and aggravation of petitioner’s injury or illness that is contained in a medical record. Section 13(b)(1). “Medical records, in general, warrant consideration as trustworthy evidence. The records contain information supplied to or by health professionals to facilitate diagnosis and treatment of medical conditions. With proper treatment hanging in the balance, accuracy has an extra premium. These records are also generally

2 contemporaneous to the medical events.” Cucuras v. Sec’y of Health & Hum. Servs., 993 F.2d 1525, 1528 (Fed. Cir. 1993).

Accordingly, where medical records are clear, consistent, and complete, they should be afforded substantial weight. Lowrie v. Sec’y of Health & Hum. Servs., No. 03- 1585V, 2005 WL 6117475, at *20 (Fed. Cl. Spec. Mstr. Dec. 12, 2005). However, this rule does not always apply. “Written records which are, themselves, inconsistent, should be accorded less deference than those which are internally consistent.” Murphy v. Sec’y of Health & Hum. Servs., No. 90-882V, 1991 WL 74931, *4 (Fed. Cl. Spec. Mstr. April 25, 1991), quoted with approval in decision denying review, 23 Cl. Ct. 726, 733 (1991), aff'd per curiam, 968 F.2d 1226 (Fed.Cir.1992)). And the Federal Circuit recently “reject[ed] as incorrect the presumption that medical records are accurate and complete as to all the patient’s physical conditions.” Kirby v. Sec’y of Health & Hum. Servs., 997 F.3d 1378, 1383 (Fed. Cir. 2021).

The United States Court of Federal Claims has outlined four possible explanations for inconsistencies between contemporaneously created medical records and later testimony: (1) a person’s failure to recount to the medical professional everything that happened during the relevant time period; (2) the medical professional’s failure to document everything reported to her or him; (3) a person’s faulty recollection of the events when presenting testimony; or (4) a person’s purposeful recounting of symptoms that did not exist. La Londe v. Sec’y of Health & Hum. Servs., 110 Fed. Cl. 184, 203-04 (2013), aff’d, 746 F.3d 1335 (Fed. Cir. 2014).

The Court has also said that medical records may be outweighed by testimony that is given later in time that is “consistent, clear, cogent, and compelling.” Camery v. Sec’y of Health & Hum. Servs., 42 Fed. Cl. 381, 391 (1998) (citing Blutstein v. Sec’y of Health & Hum. Servs., No. 90-2808, 1998 WL 408611, at *5 (Fed. Cl. Spec. Mstr. June 30, 1998). The credibility of the individual offering such fact testimony must also be determined. Andreu v. Sec’y of Health & Hum. Servs., 569 F.3d 1367, 1379 (Fed. Cir. 2009); Bradley v. Sec’y of Health & Hum. Servs., 991 F.2d 1570, 1575 (Fed. Cir. 1993).

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