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Case Law Update: Statute of Limitations in Medical Malpractice

Uldrych v. VHS of Illinois, No. 1-08-3278 (3-2-10) affirmed that actions for implied indemnity are subject to four-year period of repose in Section 13-212(a) of Code of Civil Procedure. Thus, Hospital’s implied indemnity claim against physicians, which was filed 1 1/2 years after expiration of period of repose, was properly dismissed as untimely. This Illinois case will affect medical malpractice law.