C.A. v. Secretary of Health and Human Services, 17-1033

Petitioners (parents Teresa and David Audino) filed a vaccine-injury petition alleging their daughter C.A. developed dysautonomia/POTS beginning two days after an HPV (Gardasil) vaccination on August 14, 2014.
Contemporaneous medical records do not support onset two days post-vaccination; records show relevant symptoms beginning months later (spring–summer 2015) and many exams were normal.
No medical doctor diagnosed C.A. with dysautonomia or POTS; the sole diagnosing provider was a chiropractor (George Michalopoulos) who lacks a medical degree and whose opinion the Special Master declined to credit.
Petitioners submitted later affidavits with histories inconsistent with contemporaneous medical records; the Special Master emphasized the reliability of contemporaneous records over later statements.
Petitioners conceded they could not meet their burden of proof and filed a motion to dismiss; the Special Master granted the motion and dismissed the petition.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether C.A. suffered dysautonomia/POTS caused by HPV vaccine	HPV vaccine caused C.A.’s dysautonomia/POTS with onset shortly after vaccination	Medical records and lack of qualified medical diagnosis refute vaccine causation	Dismissed: petitioners failed to prove C.A. has dysautonomia or that vaccine caused it
Credibility of non‑medical provider diagnosis	Chiropractor Michalopoulos’s diagnosis should be treated as evidentiary support	A chiropractor lacks a medical degree/training to diagnose dysautonomia; his opinion is insufficient	Held: chiropractor’s diagnosis not accepted as a medical diagnosis
Reliability of later affidavits vs contemporaneous records	Affidavits provide accurate symptom history and timing	Contemporaneous medical records are more reliable and conflict with affidavits	Held: contemporaneous records preferred; affidavits inconsistent and unpersuasive
Burden of proof under Althen/Grant (causation)	Temporal association and exclusion of other causes support causation	Need for a medical theory, reliable expert support, and proximate temporal relationship; petitioners presented none	Held: petitioners did not satisfy Althen — dismissal granted

United States v. United States Gypsum Co., 333 U.S. 364 (U.S. 1948) (contemporaneous records generally reliable)
Burns v. Secretary, HHS, 3 F.3d 415 (Fed. Cir. 1993) (records vs later testimony credibility)
Cucuras v. Secretary, HHS, 993 F.2d 1525 (Fed. Cir. 1993) (trustworthiness of medical records)
Althen v. Sec’y of HHS, 418 F.3d 1274 (Fed. Cir. 2005) (three‑part test for causation in Vaccine Program)
Grant v. Secretary of Health and Human Services, 956 F.2d 1144 (Fed. Cir. 1992) (temporal association alone insufficient; need medical theory or expert support)
Shyface v. Sec’y of HHS, 165 F.3d 1344 (Fed. Cir. 1999) (but‑for and substantial factor causation principles)