Biltz v. Marymount Hospital

Appellant’s claim is a medical claim under R.C. 2305.11(D)(3), which states:

“ ‘Medical claim’ means any claim that is asserted in any civil action against a physician, podiatrist, or hospital, against any employee or agent of a physician, podiatrist, or hospital, or against a registered nurse or physical therapist, and that arises out of the medical diagnosis, care, or treatment of any person.”

In Rome v. Flower Mem. Hosp. (1994), 70 Ohio St.3d 14, 635 N.E.2d 1239, the Ohio Supreme Court interpreted this language to include actions arising from procedures that were “ancillary” and “inherently…