Tsonis v. Anesthesiology Servs. Network, Ltd.

Citations

• 2025 Ohio 5164

Syllabus

Trial court granted summary judgment to hospital, anesthesia practice, and two medical providers on appellants' medical claims on the ground that the appellants' action was untimely. Under the 2019 amendments to R.C. 2305.113(B), appellants were not required to give actual notice of their potential claims to extend the one-year statute of limitations. Genuine issues of material fact existed on whether appellants' 180-day letters to the hospital and individual defendants were delivered within the limitations period; appellants presented evidence that the statute of limitations did not run for a period following appellant's procedure due to the effects of her related brain injury. Trial court abused its discretion in denying appellants an opportunity to conduct discovery on whether the individual defendants were out of state for personal reasons during the limitations period. Judgments reversed and remanded.