Curtis v. Secretary of Health and Human Services, 16-85

Petitioner Scott Curtis filed a Vaccine Act petition alleging a right‑shoulder SIRVA from an influenza vaccine administered November 5, 2014.
The special master entered a decision awarding compensation to petitioner based on respondent’s proffer on June 3, 2016.
Petitioner moved for attorneys’ fees and costs: fees $15,313.50, costs $593.84, plus $605.00 for preparing the reply, for a total requested award of $16,512.34.
Respondent stated she was satisfied statutory requirements for an award were met but suggested a reasonable total fee range of $12,000–$14,000 based on five prior cases; she raised no precise objections to the submitted billing.
The special master reviewed billing records, found the requested hours and rates reasonable, and awarded the full requested amount, including the $605 for the reply despite lack of line‑item entries for that time.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the requested attorneys’ fees and costs are reasonable	Requested $15,313.50 (fees) + $593.84 (costs); overall request reasonable based on counsel’s submissions and prior practice	No specific objection to entries; concedes statutory requirements met but suggests a reasonable range of $12,000–$14,000 based on prior awards	Special master found the submitted hours and rates reasonable and awarded the full requested fees and costs
Whether requested additional $605 for preparing the reply is compensable without detailed billing entries	Requests $605 (2.2 hours) for reply preparation; argues such time is reasonable	Respondent did not specifically contest this entry	Special master deemed the request reasonable despite lack of detailed billing and awarded the $605, but noted possible future reductions for similar filings

Beck v. Sec’y of Health & Human Servs., 924 F.2d 1029 (Fed. Cir. 1991) (attorney fee award in Vaccine Program precludes attorney from collecting additional fees beyond the award)