Richman v. National Health Laboratories, Inc.

In this appeal, we decide whether a clinical laboratory, which provided erroneous test results to a physician, was a “Health care provider” under Code § 8.01-581.1 et seq., the Virginia Medical Malpractice Act (the Act). Further, we decide whether the claims against the clinical laboratory were barred by the applicable statute of limitations and whether claims against a physician, who re ported the erroneous results to his patient, were the proper subject of summary judgment in favor of that physician.

On July 10, 1981, Joanne Richman visited Dr. Ward Vaughan’s office in Winchester, Virginia.…