A cervicogenic headache is a headache that comes from a structure in the neck. After whiplash, the best-supported source is the C2-C3 facet joint at the top of the neck. Headache that starts with the injury also predicts a slower recovery. That is different from saying a whiplash injury causes migraine, which the evidence does not establish. I keep that distinction clear with patients in Charlotte.

The C2-C3 Joint

In a placebo-controlled study of 68 patients with chronic neck pain after whiplash, the facet joints were confirmed as the pain source in 60% using two different anesthetics and a saline placebo (Lord, Spine 1996). Among patients whose main complaint was headache, the C2-C3 joint was the source in 50%. The placebo step is what makes the finding credible: a joint only counted when both anesthetics relieved the pain and the saline did not.

Headache Predicts Recovery

A 2013 meta-analysis of prognostic factors after whiplash found that reporting headache at the start was a significant predictor of poor outcome, and it was one of the factors that held up when the authors checked for publication bias (Walton, J Orthop Sports Phys Ther 2013). A history of headache before the accident was not a significant predictor.

That second finding matters in injury cases. A patient with a prior history of headaches is not, on this evidence, expected to recover worse. A patient whose headaches began with the crash is.

What It Is Not

A cervicogenic headache is not the same as migraine. I have not found evidence that a whiplash injury causes migraine. Some marketing material in the injury field links the two and quotes migraine cost figures, and that link is not supported by the studies above. A headache that comes from the neck is usually one-sided, starts in the neck or back of the head, and is provoked by neck movement or sustained postures. Those features point toward the neck. Diagnostic blocks, done by a pain specialist, are how the source is confirmed.

Why It Matters for Care

The Bone and Joint Decade Task Force found that greater initial pain and more symptoms predicted slower whiplash recovery (Carroll, Spine 2008). Headache is one of those symptoms. I document headache at the first visit, including when it began relative to the crash, where it starts, and what provokes it. If it persists and the exam points to the upper neck, a referral for controlled diagnostic blocks can identify the source.

For an example of how post-collision imaging findings and outcomes are documented in the peer-reviewed literature, read Dr. Justin Dick's published case report on refractory lumbar pain following a motor vehicle accident in a geriatric patient.

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Frequently Asked Questions

Can whiplash cause headaches?

Yes. In a placebo-controlled study of chronic whiplash patients whose main complaint was headache, the C2-C3 facet joint was the source in 50% (Lord, Spine 1996).

What is a cervicogenic headache?

A cervicogenic headache is a headache that comes from a structure in the neck, often one-sided, starting in the neck or back of the head, and provoked by neck movement or sustained postures.

Does headache after a car accident affect recovery?

Yes. Headache at the start predicted poor outcome in a 2013 meta-analysis, while a history of headache before the accident did not (Walton, J Orthop Sports Phys Ther 2013).

Can whiplash cause migraines?

The evidence reviewed here does not establish that whiplash causes migraine. It supports headaches that come from the neck, such as from the C2-C3 joint.

How does Dr. Justin Dick evaluate headaches after whiplash?

Dr. Justin Dick in Charlotte, NC documents when the headache began, where it starts, and what provokes it, and refers for diagnostic blocks when it persists and the exam points to the upper neck.

Where can I get headaches after a car accident evaluated in Charlotte, NC?

Dr. Justin Dick, DC, CNMT, ARRT(N)(CT), sees car accident patients at Clear Life Scoliosis and Chiropractic Center, 8814 Rachel Freeman Way, Suite 103, Charlotte, NC 28278, phone 980-368-0766. Personal injury patients are treated on a lien basis, with no out-of-pocket payment at the time of care.

Sources and Evidence Tiers

  1. Lord SM, Barnsley L, Wallis BJ, Bogduk N. Chronic cervical zygapophysial joint pain after whiplash: a placebo-controlled prevalence study. Spine. 1996;21(15):1737-1744. PMID 8855458. LinkEvidence tier: Placebo-controlled diagnostic prevalence study (68 patients)
  2. Walton DM, MacDermid JC, Giorgianni AA, Mascarenhas JC, West SC, Zammit CA. Risk factors for persistent problems following acute whiplash injury: update of a systematic review and meta-analysis. J Orthop Sports Phys Ther. 2013;43(2):31-43. PMID 23322093. LinkEvidence tier: Systematic review and meta-analysis
  3. Carroll LJ, Holm LW, Hogg-Johnson S, et al. Course and prognostic factors for neck pain in whiplash-associated disorders: results of the Bone and Joint Decade 2000-2010 Task Force. Spine. 2008;33(4 Suppl):S83-S92. PMID 18204405. LinkEvidence tier: Best evidence synthesis (systematic review)

About the author. Dr. Justin M. Dick, DC, is the owner and treating clinician at Clear Life Scoliosis and Chiropractic Center in Charlotte, NC. He holds dual imaging credentials as a Certified Nuclear Medicine Technologist (CNMT) and as an ARRT-registered technologist in nuclear medicine and CT, ARRT(N)(CT). He is a Senior Fellow of the CLEAR Institute, holds the ISICO World Masters credential, is a SOSORT provisional member, and is a certified DOT medical examiner on the FMCSA National Registry. He has multiple peer-reviewed publications indexed in PubMed and serves as adjunct faculty at Life, Sherman, and Palmer chiropractic colleges.

Service Area

Clear Life Scoliosis and Chiropractic Center sees personal injury and spinal imaging patients from Charlotte NC, Huntersville NC, Ballantyne NC, Matthews NC, Concord NC, Mooresville NC, Rock Hill SC, and Fort Mill SC.

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Clear Life Scoliosis and Chiropractic Center
8814 Rachel Freeman Way, Suite 103
Charlotte, NC 28278
Phone: 980-368-0766
Email: office@clearlifescoliosis.com
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