Pafford v. Secretary of Health and Human Services
United States Court of Appeals for the Federal Circuit
451 F.3d 1352 (Fed. Cir. 2006) (en banc)
Pafford (plaintiff) developed Juvenile Rheumatoid Arthritis (Still's disease) after receiving several vaccinations and sued the Secretary of Health and Human Services (defendant) for compensation; the Special Master found she met the first two causation elements (a reputable medical theory linking the vaccines to the disease, and that the vaccines could actually cause it) but failed to show a proximate temporal relationship between vaccination and disease onset, given other contemporaneous illnesses (a bacterial infection, sinus infection, tonsillitis, and a cold) that could equally explain the timing.
Whether a plaintiff seeking to prove injury caused by a medical vaccine must show, by a preponderance of the evidence, a medical theory connecting the vaccine to the injury, a logical cause-and-effect sequence, and a proximate temporal relationship between the vaccination and the injury.