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Ohio Case Law

Lewis v. MedCentral Health Sys., 2025-Ohio-4802

Case Information

Court: Supreme Court of Ohio
Date: 2025-10-23
Citation: 2025-Ohio-4802
Read the Opinion

Summary

Summary: The Supreme Court of Ohio held that plaintiffs in medical-claim cases may use the 180-day extension under R.C. 2323.451(D) to add additional defendants without complying with Civ.R. 15(D), and that the extension is not limited to newly discovered defendants, thereby affirming the lower court’s reversal of a dismissal.

Key Holdings

  • Plaintiffs are not required to comply with Civ.R. 15(D) to name additional defendants under R.C. 2323.451(D)(1)
  • The 180-day extension under R.C. 2323.451(D)(2) applies to any additional defendants not named in the original complaint regardless of whether they were known
  • A defendant added under R.C. 2323.451(D)(1) must not have been a party-defendant in the original complaint
  • Filing an affidavit of merit with the amended complaint satisfies the statutory requirements for invoking the extension

More Information

Christine Lewis filed a medical malpractice suit after suffering a neck fracture from a fall while medicated and unattended at Mansfield Hospital. Her original complaint named the hospital and ten unidentified John Doe defendants. Later, with the hospital’s consent, she amended the complaint to identify and name specific additional defendants, including Dr. Anand Patel and Mid-Ohio Emergency Physicians, L.L.P. These defendants moved to dismiss, arguing that the claims were barred by the one-year statute of limitations for medical claims and that Lewis failed to comply with Civ.R. 15(D), which governs fictitious names in pleadings.

The trial court agreed, dismissing the claims on the grounds that Patel and Mid-Ohio were obvious parties at the outset and that Lewis had not properly served or amended the complaint under Civ.R. 15(D). However, the Fifth District Court of Appeals reversed, finding that R.C. 2323.451(D) allowed Lewis to name these parties as additional defendants within a 180-day extension period, even if they were contemplated earlier.

On discretionary appeal, the Supreme Court of Ohio affirmed the appellate ruling. The Court concluded that R.C. 2323.451(D)(1) allows plaintiffs to amend complaints to add defendants without meeting the fictitious name requirements of Civ.R. 15(D), so long as the statutory requirements—including filing an affidavit of merit—are met. The Court emphasized that the extension is designed to allow plaintiffs time to identify and name additional medical defendants post-filing, particularly in complex cases where multiple care providers may be involved.

This decision clarifies the procedural requirements for amending complaints in medical malpractice cases and underscores the General Assembly’s intent to create an orderly discovery process without penalizing plaintiffs who initially lack full information on potential defendants.