On April 29, 2025, the Ontario Superior Court of Justice awarded over $1,000,000 in damages to a patient who suffered chronic shoulder pain following a negligently administered intramuscular tetanus injection by a resident physician. The Court found that the defendant Dr. Wang breached the standard of care by failing to landmark properly and by administering the vaccination in the wrong location. It was not administered in the middle of the deltoid as it should have been.
On December 1, 2015, Bonnie Bradley, a registered nurse with extensive experience administering and receiving vaccinations, went to receive a routine tetanus shot. Dr. Richard Wang, a first-year family medicine resident, gave the injection. During the injection, Ms. Bradley felt immediate pain in her arm. Alarmed, she turned her head and noticed that the needle appeared to be in the wrong location. In the weeks that followed, her shoulder pain persisted and worsened. Eventually, she was diagnosed with a shoulder injury that significantly limited her ability to work.
During Dr. Wang’s clerkship, he administered several deltoid intramuscular injections and was never told by his supervisors that his technique was incorrect. Given this training and the absence of complaints, Dr. Wang challenged Ms. Bradley’s account, pointing to her history of back and shoulder problems and arguing that her response to the injection didn’t match the level of pain she later reported. Ms. Bradley responded that her earlier pain was different in nature and location, and that her current symptoms only began after the injection.
Medical records show that on December 9, 2015, just over a week after the vaccination, Dr. Brankston referred Ms. Bradley to Dr. Mason, a specialist, due to concerns about possible nerve injury. Dr. Mason conducted a neurological exam, which did not reveal any nerve damage. However, Ms. Bradley reported persistent, worsening pain, limited mobility, and tingling in her thumb and index finger. She also stated that the injection was given over her shoulder joint and that the pain began immediately. Upon examination, Dr. Mason found shoulder tenderness and limited movement due to pain, which improved with support. He diagnosed rotator cuff inflammation, likely caused by the injection being placed too high near the joint.
The central question in this case is whether Dr. Wang failed to meet the expected standard of care, and if so, whether that failure directly caused Ms. Bradley’s injuries.
Dr. Ken Berger, an expert in family medicine, was called to testify on the standard of care for administering intramuscular deltoid vaccinations, including the associated risks, benefits, and potential side effects.
Dr. David Ruggles, an expert in physical medicine and rehabilitation, gave evidence on the cause and severity of soft tissue and musculoskeletal injuries, especially those involving the shoulder. He also spoke about related issues such as chronic pain, myofascial pain, nerve sensitization, and how these conditions can impact a person’s ability to work or take part in daily activities, as well as possible treatment options.
Dr. Nikolina Mizdrak, an expert in family medicine, was called to testify on the standard of care expected of family physicians when administering intramuscular deltoid injections, including the potential side effects and complications that can arise from improper technique.
Dr. Jason Smith, an expert in orthopedics, was qualified to provide an opinion on causation. His testimony addressed the concept of SIRVA, the likely cause of Ms. Bradley’s shoulder pain following the injection, and whether the injection site could be determined based on her clinical history and symptoms.
Based on the evidence, particularly that Ms. Bradley’s symptoms started immediately after the injection, the court concluded her injury was not simply a rare and unfortunate event. The quick onset of severe pain and persistent symptoms indicated improper vaccine administration rather than an uncommon inflammatory reaction.
The court emphasized that the appropriate standard of care requires correct identification of the injection site, a step the defendant failed to follow. Ms. Bradley’s testimony, supported by her treating doctors, was deemed credible and consistent with the medical evidence.
The defendant’s claims that Ms. Bradley’s prior medical history and behavior after the vaccination undermined her credibility were rejected. The court recognized that her new symptoms and limitations were distinct from any pre-existing injuries and directly linked to the vaccination injury.
Ultimately, Ms. Bradley was awarded $70,000 in general damages, $931,585 for past and future lost income, $361,600 for pension loss, along with reimbursement for out-of-pocket expenses and OHIP’s subrogated interest. The cost of future care was to be determined separately.
Decision Date: April 29, 2025
Jurisdiction: Ontario Superior Court of Justice
Citation: Bradley v. Wang, 2025 ONSC 2267
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