WARNER v. SECRETARY OF HEALTH AND HUMAN SERVICES

CourtUnited States Court of Federal Claims
DecidedJuly 7, 2025
Docket18-1952V
StatusUnpublished

This text of WARNER v. SECRETARY OF HEALTH AND HUMAN SERVICES (WARNER 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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WARNER v. SECRETARY OF HEALTH AND HUMAN SERVICES, (uscfc 2025).

Opinion

In the United States Court of Federal Claims OFFICE OF SPECIAL MASTERS No. 18-1952V

APRIL WARNER, Individually, and as Administratrix of the ESTATE OF Chief Special Master Corcoran ANDREW WARNER, Deceased, Filed: June 6, 2025 Petitioner, v.

SECRETARY OF HEALTH AND HUMAN SERVICES,

Respondent.

Charles W. Marsar, R.J. Marzella & Associates, P.C., Harrisburg, PA, for Petitioner.

James Vincent Lopez, U.S. Department of Justice, Washington, DC, for Respondent.

DECISION ON ATTORNEY’S FEES AND COSTS1

On December 20, 2018, April Warner, individually and as Administratrix of the Estate of Andrew Warner, filed a petition for compensation under the National Vaccine Injury Compensation Program, 42 U.S.C. §300aa-10, et seq.2 (the “Vaccine Act”). Petition, ECF No. 1. Petitioner alleged that her husband, Andrew Warner, suffered Guillain-Barré syndrome (“GBS”) and/or Chronic Inflammatory Demyelinating

1 Because this Decision 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 (2012). Polyneuropathy (“CIDP”) after receiving an influenza (“flu”) vaccination on or about October 5, 2015. Petition at 1. On January 31, 2024, Petitioner filed a Joint Stipulation of Dismissal, and on March 4, 2024, I issued an Order Concluding Proceedings pursuant to Vaccine Rule 21(a). Order, dated Mar. 4, 2024 (ECF No. 37).

Prior to filing the Joint Stipulation of Dismissal, Petitioner filed a motion for attorney’s fees and costs, requesting an award of $28,197.48 (representing $26,599.50 in fees plus $1,597.98 in costs). Application for Attorneys’ Fees and Costs (“Motion”) filed August 14, 2023, (ECF No. 33). Regarding Petitioner’s out-of-pocket expenses, counsel represents that “[d]espite attempts to have Petitioner sign an Order 9 statement that she incurred no costs as a result of this legal action, she has thus far refused or been unable to sign. Petitioner has incurred no costs. All costs associated with this action have been incurred by me and my firm and are attached as a separate exhibit.” Id. at 3. Respondent did not file a response to Petitioner’s Motion.

I. Relevant Procedural History

On May 19, 2020, Respondent filed his Rule 4(c) Report maintaing that this case was not appropriate for compensation. Respondent’s Rule 4(c) Report (“Report”) at 1 (ECF No. 27). Respondent concluded that Petitioner had not alleged, nor did the records support, a Vaccine Injury Table (“Table”) injury, and that Mr. Warner’s likely diagnosis of CIDP was not a compensable injury on the Table. Id. at 6. Respondent also contended that Petitioner had not demonstrated that her husband’s death was caused-in-fact by the vaccination. Id. at 8.

On January 12, 2022, I ordered Petitioner to provide any outstanding medical records, affidavits, expert reports, or other evidence supporting the conclusion that Mr. Warner was diagnosed with GBS and/or his vaccination caused-in-fact his injury/death, and that Petitioner should prevail on the merits of her claim. ECF No. 29. Petitioner never responded to that Order, however, and I subsequently ordered Petitioner to show cause as to why the case should not be dismissed for insufficient proof. ECF No. 30. The Joint Stipulation of Dismissal followed. ECF No. 36.

II. Petitioner’s Claim and Reasonable Basis

Although the Vaccine Act only guarantees a fees award to successful petitioners, a special master may also award fees and costs in an unsuccessful case if: (1) the “petition was brought in good faith”; and (2) “there was a reasonable basis for the claim for which the petition was brought.” Section 15(e)(1). I have in prior decisions set forth at

2 length the criteria to be applied when determining if a claim possessed “reasonable basis” sufficient for a fees award. See, e.g., Sterling v. Sec’y of Health & Human Servs., No. 16- 551V, 2020 WL 549443, at *4 (Fed. Cl. Spec. Mstr. Jan. 3, 2020). Importantly, establishing reasonable basis does not automatically entitle an unsuccessful claimant to fees, but is instead a threshold obligation; fees can still thereafter be limited, if unreasonable, or even denied entirely.

A claim’s reasonable basis must be demonstrated through some objective evidentiary showing. Cottingham v. Sec’y of Health & Human Servs., 971 F.3d 1337, 1344 (Fed. Cir. 2020) (citing Simmons v. Sec’y of Health & Human Servs., 875 F.3d 632, 635 (Fed. Cir. 2017)). This objective inquiry is focused on the claim—counsel’s conduct is irrelevant (although it may bulwark good faith). Simmons, 875 F.3d at 635. In addition, reasonable basis inquiries are not static—they evaluate not only what was known at the time the petition was filed, but also take into account what is learned about the evidentiary support for the claim as the matter progresses. Perreira v. Sec’y of Health & Human Servs., 33 F.3d 1375, 1377 (Fed. Cir. 1994) (upholding the finding that a reasonable basis for petitioners’ claims ceased to exist once they had reviewed their expert’s opinion, which consisted entirely of unsupported speculation). As a result, a claim can “lose” reasonable basis over time.

The standard for finding the existence of reasonable basis is lesser (and thus inherently easier to satisfy) than the preponderant standard applied when assessing entitlement, as cases that fail can still have sufficient objective grounding for a fees award. Braun v. Sec’y of Health & Human Servs., 144 Fed. Cl. 72, 77 (2019). The Court of Federal Claims has affirmed that “[r]easonable basis is a standard that petitioners, at least generally, meet by submitting evidence.” Chuisano v. Sec’y of Health & Human Servs., 116 Fed. Cl. 276, 287 (Fed. Cl. 2014) (internal quotations omitted) (affirming special master). The factual basis and medical support for the claim is among the evidence that should be considered. Carter v. Sec’y of Health & Human Servs., 132 Fed. Cl. 372, 378 (Fed. Cl. 2017). Under the Vaccine Act, special masters have “maximum discretion” in applying the reasonable basis standard. See, e.g., Silva v. Sec’y of Health & Human Servs., 108 Fed. Cl. 401, 401–02 (Fed. Cl. 2012).

Here, I find that Petitioner’s claim had sufficient objective basis to entitle her to a fee award. Claims that vaccines can cause GBS and CIDP are common enough in the Program to have facial credibility.

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