Beckham v. Secretary of Health and Human Services, 15-940

Petitioner filed a Vaccine Act claim alleging Guillain–Barré Syndrome after a 9/22/2014 influenza vaccination; case filed 8/27/2015.
The parties stipulated to compensation; Chief Special Master issued a decision awarding damages on 9/26/2016.
Petitioner then moved for attorneys’ fees and costs on 1/5/2017, seeking $34,663.60 in fees and $2,096.44 in costs (total $36,760.04).
Petitioner indicated no out-of-pocket expenses as required by General Order No. 9.
Respondent declined a substantive role in fee resolution but stated the statutory requirements for an award were met and left the amount to the Special Master’s discretion.
The Chief Special Master reviewed billing records, found the request reasonable, and granted the full requested amount, ordering payment jointly to petitioner and counsel.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether petitioner is entitled to reasonable attorneys’ fees and costs under the Vaccine Act	Petitioner seeks $36,760.04 as reasonable attorneys’ fees and costs incurred in the successful claim	Respondent agrees statutory requirements are met but asserts no formal role in resolving fee amounts; defers to Special Master discretion	Awarded: full requested amount ($36,760.04) granted as reasonable
Whether the requested hours and rates are reasonable	Billing records support requested hours and rates; petitioner defended reasonableness in reply	Respondent did not contest reasonableness of hours or rates	Held reasonable; no reductions made
Form of payment and scope of award	Petitioner requested payment to counsel’s firm	Respondent did not object; Special Master noted award covers all legal expenses and precludes additional fees	Check jointly payable to petitioner and counsel; award encompasses all charges and advanced costs

Beck v. Sec’y of Health & Human Servs., 924 F.2d 1029 (Fed. Cir. 1991) (attorney may not collect fees in addition to the amount awarded under the Vaccine Act)