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Kelty v. Genovese Drug Stores, Inc.

Citation: 2023 NY Slip Op 01282Docket: 2020-03749

Court: Appellate Division of the Supreme Court of the State of New York; March 15, 2023; New York; State Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

This case involves a medical malpractice lawsuit filed by a plaintiff against a drug store and a physician, alleging injuries from a reduced medication dosage prescribed for hypothyroidism. The prescription was allegedly unclear, leading to a drop from 200 micrograms to 25 micrograms. The Supreme Court of Suffolk County dismissed the complaint against the physician as time-barred under the 2½-year statute of limitations applicable to medical malpractice claims. The plaintiff contended that the claim should fall under ordinary negligence, which would allow for a longer statute of limitations. However, the Appellate Division, Second Department, affirmed the lower court’s decision, holding that the claim was rooted in medical treatment, thus correctly categorized as medical malpractice. The appellate court underscored that the duty owed by the physician related directly to medical care, which substantiated the application of the medical malpractice statute of limitations. Consequently, the complaint was dismissed, and costs were awarded to the respondent, with the decision being unanimous among the justices.

Legal Issues Addressed

Distinction Between Medical Malpractice and Ordinary Negligence

Application: The court determined that the allegations related to the physician's medical treatment, thereby classifying the claims under medical malpractice rather than ordinary negligence, which affected the applicable statute of limitations.

Reasoning: The court clarified that negligent acts by healthcare providers that relate to medical treatment fall under medical malpractice.

Duty Owed by Healthcare Providers

Application: The decision hinged on the nature of the duty owed by the physician, affirming that duties related to medical treatment are subject to medical malpractice standards.

Reasoning: The Appellate Division, Second Department, affirmed the lower court's decision, emphasizing that the determination hinges on the nature of the duty owed by Hito to Kelty.

Statute of Limitations for Medical Malpractice Claims

Application: The court applied the 2½-year statute of limitations for medical malpractice claims, resulting in the dismissal of the complaint against the physician as time-barred.

Reasoning: On May 5, 2020, the Supreme Court of Suffolk County granted Hito's motion for summary judgment, dismissing the complaint against him as time-barred under the 2½-year statute of limitations for medical malpractice claims.