SANCHEZ v. SECRETARY OF HEALTH AND HUMAN SERVICES

United States Court of Federal Claims·Decided March 18, 2026·No. 11-0685V·Unpublished

Opinion

In the United States Court of Federal Claims OFFICE OF SPECIAL MASTERS

************************* GERMAIN SANCHEZ and * JENNIFER SANCHEZ, * parents of T.S., * * No. 11-685V Petitioners, * Special Master Christian J. Moran v. *

*

SECRETARY OF HEALTH * Filed: February 17, 2026 AND HUMAN SERVICES, *

*

Respondent. *

*************************

Lisa A. Roquemore, Law Offices of Lisa A. Roquemore, Rancho Santa Margarita, CA, and Richard Gage, Richard Gage, P.C., Cheyenne, WY, for petitioners; Jennifer L. Reynaud, Zoey Wade, and Madylan Yarc, United States Dep’t of Justice, Washington, DC, for respondent.

ORDER REGARDING RESPONDENT’S MOTION TO REOPEN AND MOTION FOR SANCTIONS1

Germain and Jennifer Sanchez filed this case in 2011, claiming that various childhood vaccinations given to their son, T.S., on February 5, 2009, harmed him by causing a neurologic problem. Pet., filed Oct. 17, 2011. A critical issue was when T.S. first displayed any symptoms of a neurologic problem.

After litigation lasting more than a decade, the Federal Circuit found, as a fact, that T.S.

started having neurologic problems, specifically abnormal arm movements, close in time to the vaccinations. The Federal Circuit primarily relied upon testimony from Mr. and Ms. Sanchez,

1 Because this order contains a reasoned explanation for the action in this case, the undersigned is 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 order will be available to anyone with access to the internet. In accordance with Vaccine Rule 18(b), the parties have 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, the undersigned agrees that the identified material fits within this definition, the undersigned will redact such material before posting the decision.

given first by affidavit in 2011 and later by oral testimony in 2012 (fact hearing). Based upon this finding, the Federal Circuit found that Mr. and Ms. Sanchez were entitled to compensation. 34 F.4th 1350 (Fed. Cir. 2022).

In 2023, while investigating the amount of compensation to which Mr. and Ms. Sanchez were entitled, the Secretary received medical records that Mr. and Ms. Sanchez should have produced years and years earlier. The Secretary grounds the pending motion to reopen the issue of entitlement upon his recent discovery of previously available evidence, arguing that this evidence is sufficient to undermine the previous finding of fact. The Sanchezes maintain that the newly produced evidence is cumulative with previous evidence. The Sanchezes also argue that their failure to produce documents is excused because the Secretary should have requested the missing documents earlier in the litigation

The Secretary also moved for an imposition of sanctions on the Sanchezes due to their and their attorney’s alleged misconduct with respect to the preservation and production of evidence. The Secretary moved for dismissal or, in the alternative, an order granting an adverse inference. Mr. and Ms. Sanchez opposed the motion for sanctions.

The Secretary has satisfied the standards for reopening entitlement because the medical records produced in 2023 constitute newly discovered evidence that warrant a departure from the Federal Circuit’s mandate. Mr. and Ms. Sanchez and their attorney, Lisa Roquemore, were responsible for the failure to file crucial medical records in 2011. Thus, the argument that the Secretary is responsible for the absence of missing records is not persuasive. Further, upon a reopening of entitlement, preponderant evidence supports finding that T.S.’s initial abnormal arm movements occurred months later than previously found. Whether this change in fact-finding results in a change in outcome will be determined later.

As discussed below, the Secretary has deferred any request for sanctions until Mr. and Ms. Sanchez seek additional attorneys’ fees and costs. The Secretary’s motion for sanctions is therefore denied as moot.

The outline of this lengthy opinion is as follows:

I. The Process by Which Medical Records are Submitted ............................................. 3 II. Procedural History ...................................................................................................... 5 III. Analysis Part One: Motion to Reopen .................................................................. 19 IV. Analysis Part Two: Findings of Facts ................................................................... 35 V. Analysis Part Three: Motion for Sanctions ............................................................... 66 VI. Conclusion ............................................................................................................ 66

I. The Process by Which Medical Records are Submitted

For the motion to reopen and the motion for sanctions, the key issue concerns the production of medical records. Thus, the law regarding the duties for submitting medical records is explained as a foundation for the analysis that follows. By way of background, the Vaccine Program is intended to be “less adversarial.” Vaccine Rule 3(b)(2). Congress’s plan to create a less adversarial process for resolving claims that a vaccine injured someone is reflected in several aspects of the Vaccine Act.

Congress directed that when a petition is filed, the petition “shall contain … (2) pre- and post-injury physician or clinic records (including all relevant growth charts and test results), all post-injury inpatient and outpatient records (including all provider notes, tests results, and medication records).” 42 U.S.C. § 300aa–11(c). This statutory requirement is at center of the parties’ dispute regarding whether entitlement should be reopened.

As to the scope of material to be filed with a petition, judicial officers offered some instructions. First, the judges of the Court of Federal Claims promulgated the Vaccine Rules. Citing 42 U.S.C. § 300aa–11(c), the Vaccine Rules require petitioners to present medical records relating to “any post-vaccination treatment of the injured person, including all in-patient and out- patient records.” Vaccine Rule 2(c)(2)(A)(iii).

Second, special masters authored a set of Guidelines, which detail the types of medical records expected to be filed. In the 2004 version, which was in place at the time the Sanchezes filed their petition, the Guidelines provided:

The statute at § 11(c) explicitly sets forth the required documents, as does Vaccine Rule 2(c). The scope of the requirements is, intentionally, very broad. Counsel should include all medicallyrelated records that might possibly shed light on the question of causation. Indeed, in the typical case where the vaccine recipient was an infant when vaccinated, the petition should include all medical records relating to the pregnancy and resulting delivery, as well as records pertaining to the infant’s entire lifetime prior to the vaccination, including those of “well baby” visits. In addition, the petition must contain in every case all records pertaining to the vaccination itself and all post-vaccination medical examination and treatment records of the individual.

In short, if there is any doubt whether a record falls within the above description, it should be included.

Section II.B.1.2 Through the Guidelines, the special masters also added: “If petitioner has doubts about the relevance of requested records, petitioner should keep in mind that the standard used for determining relevance will ordinarily be a quite liberal one, i.e., whether the requested records might shed light upon any issues relating to petitioner’s claim.” Section III.3

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