Specific Fee Shifting Statute: Plaintiff’s Untimely Vaccine Petition Did Not Mean She Could Not Recover Fees Under National Childhood Vaccine Injury Act

 

The United States Supreme Court in Sebelius v. Cloer, No. 12-236 (U.S. May 20, 2013) has spoken.

Health in a U.S. city - a serum and vaccine farm. Children await inoculation

     Children await inoculation.  1944.  Library of Congress.

     In this case, plaintiff filed a petition to recovery for injuries due to vaccines under the National Childhood Vaccine Injury Act. However, a special master found the petition to be untimely and denied plaintiff’s request for $118,000 in attorney’s fees.

     Fee denial reversed. 42 U.S.C. § 300aa-15(e)(1) provides that even an unsuccessful petitioner can recover discretionary fees if the unsuccessful petition was brought in good faith and with a reasonable basis. Even though petitioner did not prevail, the untimely nature of her petition was not a barrier to recovery of fees.

     Link to SCOTUSblog opinion analysis.

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