Oldfield v. Secretary of Health and Human Services, 15-1035

Petitioner Angeline Oldfield filed a Vaccine Program claim alleging SIRVA (debilitating left shoulder pain and restricted ROM) caused by an October 7, 2013 trivalent influenza vaccination.
The special master entered a compensation decision based on respondent’s proffer on May 18, 2016, which petitioner accepted.
Petitioner moved for attorneys’ fees and costs on September 29, 2016, initially seeking $17,859.97 (later corrected).
Respondent filed a response stating she believed statutory requirements for an award were met but suggested a reasonable range of $12,000–$14,000 without detailed justification.
Petitioner filed an amended fees motion correcting the total to $18,159.97 and replied defending the contemporaneous billing, necessity, and reasonableness of the requested fees.
The special master found the requested fees and costs reasonable and awarded a total of $18,159.97: $17,589.39 (fees and costs) payable jointly to petitioner and counsel, and $570.58 (petitioner’s out-of-pocket costs) payable to petitioner.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether petitioner is entitled to an award of attorneys’ fees and costs under the Vaccine Act	Oldfield sought reimbursement for attorneys’ fees and costs incurred prosecuting the claim; submitted contemporaneous billing and out-of-pocket expense statement	Respondent did not contest entitlement and acknowledged statutory requirements were met	Award of attorneys’ fees and costs granted under 42 U.S.C. § 300aa-15(e)
Whether the amount requested is reasonable	Oldfield argued all fees were contemporaneously billed, necessary, and reasonable; submitted hourly rates and billing records	Respondent recommended a lower range ($12,000–$14,000) but provided little explanation or itemized objection	Special master found the requested amount reasonable and awarded $18,159.97 in total
Proper allocation and form of payment	Petitioner requested reimbursement to counsel and reimbursement to petitioner for costs	Respondent did not dispute allocation or form of payment	Ordered lump sum $17,589.39 payable jointly to petitioner and counsel, and $570.58 payable to petitioner
Whether attorney may later collect additional fees beyond this award	N/A	N/A	Noted that the award is intended to cover all legal expenses and attorney may not charge additional fees (citing precedent)

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