Perhaps she has a muscle or joint injury. I have a little hen that was injured, and it keeps flaring up. I separate her when she seems sore. Her problem started when somebody opened the pen one day while I was at work. I think they tried to catch her and injured her.
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It could be Marek's. If it hit them quickly, it could be a very strong strain. The only way to know for sure is to get a necropsy done. Most state universities can facilitate that at a reasonably low cost. Your local extension agent can probably give you more information about where...
Has there been any studies done on this? Does it "cure" or just alleviate symptoms. Marek's is a disease that is normally considered in remission, rather than cured, when a bird seems to recover.