Brown v. Kindred Nursing Centers East, LLC

BRADY, Justice.

This case presents the question whether a complaint alleging medical malpractice may be amended after the expiration of the two-year statute of limitations to include an expert certification as required by North Carolina Rule of Civil Procedure 9(j) (Rule 9(j)). We have previously held that “[a]llowing a plaintiff to file a medical malpractice complaint and to then wait until after the filing to have the allegations reviewed by an expert would pervert the purpose of Rule 9(j).” Thigpen v. Ngo, 355 N.C. 198, 204, 558 S.E.2d 162, 166-67 (2002). Because our decision in Thigpen…