Wiles v. Secretary of Health and Human Services

United States Court of Federal Claims·Decided May 27, 2026·No. 22-0399V·Unpublished

Opinion

In the United States Court of Federal Claims OFFICE OF SPECIAL MASTERS No. 22-399V

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AMANDA WILES, * Chief Special Master Corcoran

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Petitioner, * Filed: April 23, 2026

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v. *

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SECRETARY OF HEALTH AND * HUMAN SERVICES, *

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Respondent. *

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Christopher J. Webb, Black McLaren Jones Ryland & Griffee, PC, Memphis, TN, for Petitioner.

Ryan Daniel Pyles, U.S. Dep’t of Justice, Washington, DC, for Respondent.

DECISION GRANTING IN PART FINAL AWARD OF ATTORNEY’S FEES AND COSTS1

On April 7, 2022, Amanda Wiles filed a petition for compensation under the National Vaccine Injury Compensation Program (the “Vaccine Program”).2 Petition (ECF No. 1) at 1. Petitioners alleges that she developed a seizure disorder after receipt of tetanus-diphtheria-acellular pertussis (“Tdap”) and influenza (“flu”) vaccines on October 3, 2019, or that her condition (to the extent it predated vaccination) was significantly aggravated by these vaccines. Id. The parties briefed their positions, and I issued a decision denying entitlement on December 9, 2025. Decision, dated Dec. 9, 2025 (ECF No. 58). That Decision was not appealed, and judgment has since entered.

Petitioner has now filed a motion for a final award of attorney’s fees and costs. Motion, dated Feb. 26, 2026 (ECF No. 63) (“Mot.”). This is Petitioner’s sole such request. Petitioner

1 Under Vaccine Rule 18(b), each party has fourteen (14) days within which to request redaction “of any information furnished by that party: (1) that is a trade secret or commercial or financial in substance and is privileged or confidential; or (2) that includes medical files or similar files, the disclosure of which would constitute a clearly unwarranted invasion of privacy.” Vaccine Rule 18(b). Otherwise, the whole Decision will be available to the public in its present form. Id. 2 The Vaccine Program comprises Part 2 of the National Childhood Vaccine Injury Act of 1986, Pub. L. No. 99-660, 100 Stat. 3755 (codified as amended at 42 U.S.C. §§ 300aa-10–34 (2012)) (hereinafter “Vaccine Act” or “the Act”). All subsequent references to sections of the Vaccine Act shall be to the pertinent subparagraph of 42 U.S.C. § 300aa.

requests fees and costs relating to the work performed by present counsel (Christopher J. Webb of Black, McLaren, Jones, Ryland & Griffee), since his appearance in the matter, as well as fees and costs relating to the work performed by prior counsel (Ronald C. Homer of Conway, Homer, P.C.). Petitioner requests a total of $261,096.21—$220,295.31 for Mr. Webb ($133,537.20 in fees, plus expenses in the amount of $86,758.11), and $40,800.90 for Conway Homer P.C. ($34,919.10 in fees and $5,881.80 in costs). Mot. at 14; ECF No. 63-4 at 1–3.

Respondent reacted to Petitioner’s Motion, deferring to my discretion as to whether Petitioner has met the legal and statutory requirements for a fees and costs award, as well as the calculation of the amount to be awarded. See Response, dated Mar. 4, 2026 (ECF No. 65) at 2.

For the reasons set forth below, I hereby GRANT IN PART Petitioner’s motion, awarding fees and costs in the total amount of $249,034.23 ($208,233.33 for Petitioner’s current counsel, and $40,800.90 for former counsel).

ANALYSIS

I. Petitioner’s Claim has 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 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 & Hum. 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 & Hum. Servs., 971 F.3d 1337, 1344 (Fed. Cir. 2020) (citing Simmons v. Sec’y of Health & Hum. 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 & Hum. 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 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 & Hum. 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 & Hum. 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 & Hum. 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 & Hum. Servs., 108 Fed. Cl. 401, 401–02 (Fed. Cl. 2012).

Petitioner’s claim was ultimately unsuccessful, but there was sufficient objective basis to entitle her to a fees and costs award. There was some record evidence that Petitioner experienced seizures and was diagnosed with epilepsy after receiving Tdap and flu vaccines. Petitioner’s epilepsy diagnosis was also uncontested (although it was not found to be an autoimmune variant). Thus, and in light of the exceedingly lenient standard that governs reasonable basis determinations, a final award of fees and costs in this matter is permissible. And because I find no reason otherwise to deny a fees award, I will allow one herein.

II. Calculation of Fees

Only “reasonable” fees or costs may be awarded in the Program. Determining the appropriate amount of the fees award is a two-part process. The first part involves application of the lodestar method—“multiplying the number of hours reasonably expended on the litigation times a reasonable hourly rate.” Avera v. Sec’y of Health & Hum. Servs, 515 F.3d 1343, 1347–48 (Fed. Cir. 2008) (quoting Blum v. Stenson, 465 U.S. 886, 888 (1984)). The second part involves adjusting the lodestar calculation up or down to take relevant factors into consideration. Id. at 1348. This standard for calculating a fee award is considered applicable in most cases where a fee award is authorized by federal statute. Hensley v. Eckerhart, 461 U.S. 424, 429–37 (1983).

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