WILLIAMS v. SECRETARY OF HEALTH AND HUMAN SERVICES

In the United States Court of Federal Claims
OFFICE OF SPECIAL MASTERS
No. 24-1560V
CARROLL WILLIAMS,
Petitioner,
v.
SECRETARY OF HEALTH AND
HUMAN SERVICES,
Respondent.
Chief Special Master Corcoran
Filed: December 19, 2025
Laura Levenberg, Muller Brazil, LLP, Dresher, PA, for Petitioner.
Joseph Douglas Leavitt, U.S. Department of Justice, Washington, DC, for Respondent.
DECISION ON JOINT STIPULATION1
On October 2, 2024, Carroll Williams 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 shoulder injury related to vaccine
administration (“SIRVA”) following a Tdap vaccination she received on November 16,
2023. Petition at 1; Stipulation, filed at December 18, 2025, ¶¶ 2, 4. Petitioner further
alleges that her “SIRVA symptoms persisted for more than six months.” Petition at ¶ 9;
Stipulation at ¶ 4. “Respondent denies that Petitioner sustained a SIRVA Table injury and
denies that the vaccine caused her alleged shoulder injury, or any other injury.” Stipulation
at ¶ 6.
Nevertheless, 	on 	December 	18, 	2025, 	the 	parties 	filed 	the 	attached 	joint
stipulation, 3 stating that a decision should be entered awarding compensation. I find the
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 (2018).
3 The filed Stipulation included an electronic signature page that has been removed from the attachment
to protect the confidential information of the signers.
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2
stipulation reasonable and adopt it as my decision awarding damages, on the terms set
forth therein.
Pursuant to the terms stated in the attached Stipulation, I award the following
compensation:
A lump sum of $37,517.53, to be paid through an ACH deposit to Petitioner’s
counsel’s IOLTA account for prompt disbursement to Petitioner. Stipulation
at ¶ 8. This amount represents compensation for all items of damages that would
be available under Section 15(a). Id.
I approve the requested amount for Petitioner’s compensation. In the absence of
a motion for review filed pursuant to RCFC Appendix B, the Clerk of Court is directed to
enter judgment in accordance with this decision. 4
IT IS SO ORDERED.
s/Brian H. Corcoran
Brian H. Corcoran
Chief Special Master
4 Pursuant to Vaccine Rule 11(a), entry of judgment can be expedited by the parties’ joint filing of notice
renouncing the right to seek review.
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Vinesign Document ID: C4947400-E517-4262-9858-97E2FE6A8F48
IN THE UNITED STATES COURT OF FEDERAL CLAIMS
OFFICE OF SPECIAL MASTERS
CARROLL WILLIAMS,
Petitioner,
V. 	No. 24-1560V (ECF)
Chief Specia l Master Corcoran
SECRETARY OF HEALTH AND
HUMAN SERVICES,
Respondent.
STIPULATION
The parties hereby stipulate to the following matters:
I. 	On October 2, 2024, petitioner filed a petition for vaccine compensation under the
National Vaccine Injury Compensation Program , 42 U.S.C. § 300aa-l Oto -34 (the "Program").
The petition seeks compensation for an injury a ll eged ly related to petitioner's receipt of the
tetanus, diphtheria, and ace llular pertussis ("Tdap") vaccine , which vacc in e is contained in the
Vaccine Injury Table, 42 C.F.R. § 100.3(a) (the "Table").
2. 	Petitioner received a Tdap vaccine on November 16, 2023.
3. 	The vaccine was administered within the United States.
4. 	Petitioner alleges that she suffered a right-sided shou ld er injury related to vaccine
administration (" SIRVA") as a result of her vaccination . Petitioner further alleges that she
experienced the residual effects of this injury for more than six months.
5. 	Petitioner represents that there has been no prior award or settlement of a c ivil action for
damages as a result of her alleged injury.
The signed document can be validated at https://app.vinesign.com/Verify
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6. 	Respondent denies that petitioner sustained a SIRVA Table injury and denies that the
vaccine caused her alleged shoulder injury, or any other injury.
7. 	Maintaining their above-stated positions, the parties nevertheless now agree that the
issues between them shall be settled and that a decision should be entered awarding the
compensation described in paragraph eight of this Stipulation.
8. 	As soon as practicable after an entry of judgment reflecting a decision consistent with the
terms of this Stipulation, and after petitioner has filed an election to receive compensation
pursuant to 42 U.S.C. § 300aa-21 (a)(]), the Secretary of Health and Human Services will issue
the following vaccine compensation payment:
A lump sum payment of $37,517.53 to be paid through an ACH deposit to
petitioner 's counsel's IOLTA account for prompt disbursement to petitioner. This
amount represents compensation for all damages that would be available under 42
U.S.C. § 300aa-15(a).
9. 	As soon as practicable after the entry of judgment on entitlement in this case, and after
petitioner has filed both a proper and timely election to receive compensation pursuant to 42
U.S.C. § 300aa-21 (a)(l), and an application, the parties will subm itto further proceedings before
the special master to award reasonable attorneys' fees and costs incutTed in proceeding upon this
petition .
I 0. Petitioner and her attorney represent that the compensation to be provided pursuant to
this Stipulation is not for any items or services for which the Program is not primarily liable
under 42 U.S.C. § 300aa-15(g), to the extent that payment has been made or can reasonably be
expected to be made under any State compensation programs, insurance policies, Federal or
State health benefits programs (other than Title XIX of the Social Security Act (42 U.S.C.
§ 1396 et seq.)), or by entities that provide health services on a pre-paid basis.
2
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11. Payment made pursuant to paragraph eight and any amounts awarded pursuant to
paragraph nine of this Stipulation will be made in accordance with 42 U.S.C. § 300aa-l 5(i),
subject to the avai lability of suffic ient statutory funds.
I 2 . The parties and their attorneys further agree and stipu late that, except for any award for
attorneys' fees and litigatio n costs, and past unreimbursed expenses, the money provided
pursuant to this Stipulation will be used solely for the benefit of petitioner as contemplated by a
strict construction of 42 U.S .C. § 300aa- 15(a) and (d), and subject to the conditions of 42 U.S.C.
§ 300aa- 15(g) and (h).
13. In return for the compensation described in paragraphs e ight and nine, petitioner, in h er
individual capacity, and on behalfof her heirs, executors, administrators, successors, or assigns,
does forever and irrevocably and un conditio nally re lease, acquit , and discharge the United States
and the Secretary of Health and Human Services from any and a ll act ion s or causes of action
(including agreements,judgments, claims, damages, lo ss of services, expenses, and a ll demands
of whatever kind or nature) that hav e been brought, could have been brought, or cou ld be timely
brought in the Court of Federal Claims, under the Nationa l Vaccine Injury Compensat ion
Program, 42 U .S.C. § 300aa- IO et seq., on account 01: or in any way growing out of, any and all
known or unknown , suspected or unsuspected personal injuries to or death of petitioner resulting
from, or alleged to have resulted from , the Tdap vaccination administered on November 16,
2023, as alleged in a petition for vaccine compensation filed on or about October 2, 2024, in the
Un it ed States Court of Federal C laim s as petition No. 24- 1560V.
14. If petitioner should die prior to entry of judgment , this agreement shall be voidable upon
proper notice to the Court on behalf of either or both of the parties.
3
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15. If the Chief Special Master fai ls to issue a decision in comp lete conformity with the
terms of this Stipulation or if the Co urt of Federa l Claims fails to enter judgment in conformity
with a decision that is in complete conformity with the terms of this Stipulation , then the patties'
settlement and this Stipu lation sha ll be voidable at the so le discretion of either party.
16. This Stipu lat ion expresses a full and complete negotiated settlement of li ability and
damages claimed under the National Childhood Vaccine Injury Act of 1986, as amended, except
as otherwise noted in paragraph nine above. There is abso lutely no agreement on the part of the
parties hereto to make any payment or to do any act or thing other than is herein express ly stated
and c lear ly agreed to. The parties further agree and understand that the award described in this
Stipu lation may reflect a comprom ise of the parties ' respective positions as to li ability and/ or
amount of damages, and further, that a change in the nature of the injury or condit ion or in the
items of compensation sought , is not grounds to modify or revise this agreement.
17. This Stipulation sha ll not be construed as an admission by the United States or the
Secretary of Health and Human Services that the flu vaccine caused petitioner' s a ll eged shou Id er
injury or any other injury , or that she suffered an injury contained in the Vaccine Injury Table.
18. A ll rights and obligations of petitioner hereunder sha ll apply equa ll y to petitioner' s heirs,
executors , administrators, successors , and/or assigns.
END OF STIPULATION
4
Case 1:24-vv-01560-UNJ Document 30 Filed 01/27/26 Page 6 of 7

Respectfully submitted ,
PETITIONER:
CARROLL WILLIAMS
ATTORNEY OF RECORD FOR
PETITIONER:
~~LAURA LEV ENBERG
Muller Brazil
715 Twining Road
Suite 208
Dresher , PA 19025
Telephone : (215) 885-1655
laura@ mullerbrazil.com
AUTHORIZED REPRESENTATIVE OF
THE SECRET ARY OF HEAL TH AND
HUMAN SERVICES:
Jeffrey S. Digitally signed by Jeffrey
S. Beach -5
AUTHORIZED REPRESENTATIVE
OF THE ATTORNEY GENERAL:
~\kR-L~
HEATHER L. PEARLMAN
Deputy Director
Torts Branch
Civil Division
U.S. Depaitment of Ju stice
P.O. Box 146
Benjamin Franklin Station
Washington , D.C.20044-0146
ATTORNEY OF RECORD FOR
RESPONDENT:
Beach -S 	Date: 2025. 12.11 09:51:16
_ 	_ 	_____ 	-os·oo· 	for - --1-------------
CAPT GEORGE REED GRIMES, MD, MPH
Director, Division of Injury
Compensation Programs
Health Systems Bureau
Health Resources and Services
Administration
U.S. Depa1tment of Health
and Human Services
5600 Fishers Lane , 14W-l 8
Rockville, MD 20857
5
Civil Division
U.S. Department of Ju stice
P.O. Box 146
Benjamin Franklin Station
Washington, D.C.20044-0146
(202) 880 - 0390
joseph.leavitt @ usdoj.gov
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