Cynthia La Londe, Parent of M.L., a Minor v. Secretary of Health and Human Services, 110 Fed. Cl. 184

Petitioner alleges her child M.L. suffered vaccine-related neurological injuries from a DTaP vaccination under the Vaccine Act.
Special master denied compensation in 2012 after evaluating causation theories and the record.
Petitioner relied on Dr. Kinsbourne’s two-phase anaphylaxis theory linking initial reaction to focal brain injury and seizures.
Record includes extensive medical history, hospitalizations, EEGs, and post-vaccination events from April 2005 onward.
Court conducting review under 42 U.S.C. § 300aa-12(e)(2) and Vaccine Rule 24; Petitioner appeals on causation, credibility, and evidence issues.
Court ultimately sustains the special master’s denial, finding no reliable causal link and unresolved evidentiary gaps.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Althen prong I is satisfied	La Londe argues Dr. Kinsbourne’s theory shows causation-in-fact.	La Londe fails to provide a reliable medical theory linking vaccine to injury.	No, petitioner failed to prove a reliable medical theory.
Whether Althen prong II is satisfied	Evidence shows inflammation/edema and timing support a causal sequence.	Record lacks a proven mechanism linking the vaccine reaction to focal brain injury; expert relied on unsupported assumptions.	No, petitioner failed to show a logical sequence linking vaccination to injury.
Whether Althen prong III (temporal relationship) is sufficient	There is a clear temporal relationship between vaccination and neurological events.	Temporal relation alone does not establish causation without Prongs I–II satisfied.	No, temporal proximity alone is insufficient to prove causation.
Whether the special master properly handled credibility and petitioner’s narrative/affidavit	The master improperly discounted petitioner’s accounts and relied on expert credibility.	The master validly rejected unreliable expert testimony; credibility determinations were appropriate.	No reversible error; credibility findings and handling were not arbitrary.

Althen v. Sec’y of HHS, 418 F.3d 1274 (Fed. Cir. 2005) (three-prong test for showing causation-in-fact under Vaccine Act)
Capizzano v. Sec’y of HHS, 440 F.3d 1317 (Fed. Cir. 2006) (logical sequence of cause and effect; treatment of medical evidence)
Moberly v. Sec’y of HHS, 592 F.3d 1315 (Fed. Cir. 2010) (reliance on biological mechanisms; require some evidence at work in patient)
Andreu v. Sec’y of HHS, 569 F.3d 1367 (Fed. Cir. 2009) (credibility and evidentiary standards in Vaccine Act review)
Doe v. Sec’y of HHS, 601 F.3d 1349 (Fed. Cir. 2010) (understanding of review of expert testimony in causation findings)