Hinton v. Hhs
23-2161
Fed. Cir.Mar 11, 2025Background
- Shawn’Quavious Hinton’s mother, Tramella Hinton, alleged that her son received a flu vaccine on December 21, 2015, at his primary care physician Dr. Alligood’s office.
- Clinic records marked Shawn as a "no show" for the December 21 appointment, and insurance/Medicaid records did not show a charge for a visit or vaccine that day.
- Shawn developed Guillain-Barré syndrome (GBS) in February 2016, leading to a claim for compensation under the National Vaccine Injury Compensation Program (Vaccine Act).
- The special master credited Ms. Hinton’s detailed and persistent efforts as evidence supporting her claim, despite missing or contradictory medical documentation.
- The special master found that, by a preponderance of the evidence, Shawn received the flu vaccine as claimed; the Secretary appealed, arguing this finding was arbitrary and capricious.
- The Claims Court upheld the special master; the Secretary appealed to the Federal Circuit.
Issues
| Issue | Hinton's Argument | Secretary's Argument | Held |
|---|---|---|---|
| Did Shawn receive a flu vaccine on Dec. 21, 2015? | Hinton’s testimony and circumstantial evidence establish vaccination despite absent records. | No contemporaneous medical record supports vaccination; medical records suggest otherwise. | The special master's finding was plausible; factual finding upheld. |
| Was the special master’s reliance on testimony over records arbitrary/capricious? | Special master properly weighed all evidence, finding Hinton credible. | Weighing later testimony over conflicting records is irrational and improper. | Not arbitrary/capricious to credit testimony given the evidence and circumstances. |
| Do gaps/inconsistencies in records undermine plausibility of vaccination? | Lax clinic procedures could explain missing/misentered documentation; plausible that errors occurred. | Missing/contrary records make vaccination highly implausible; circumstantial account insufficient. | Not implausible; special master's finding supported by evidence, even if weak. |
| Did the special master articulate a rational basis for her findings? | Yes, detailed rationale provided for crediting testimony and evaluating evidence. | No sufficient rationale for preferring testimony over records; decision lacks reasoned explanation. | Decision explained and reasoned; not arbitrary or capricious. |
Key Cases Cited
- Lampe v. HHS, 219 F.3d 1357 (Fed. Cir. 2000) (standard for reviewing factual findings in Vaccine Act cases is highly deferential; arbitrary and capricious standard)
- Hines ex rel. Sevier v. HHS, 940 F.2d 1518 (Fed. Cir. 1991) (reversible error is difficult to demonstrate if special master considers relevant evidence and provides rational basis)
- Porter v. HHS, 663 F.3d 1242 (Fed. Cir. 2011) (credibility assessments and factual findings are within the special master's purview)
- Hodges v. HHS, 9 F.3d 958 (Fed. Cir. 1993) (table injuries under Vaccine Act confer presumed causation and deferential review of fact findings)
- Saunders v. HHS, 25 F.3d 1031 (Fed. Cir. 1994) (Claims Court must uphold special master unless arbitrary or capricious)
- Munn v. HHS, 970 F.2d 863 (Fed. Cir. 1992) (arbitrary and capricious standard is the most deferential possible)