Tenet Healthsystem Gb, Inc. v. Thomas.

Summary

The court held that review of a relation-back determination under the applicable pleading rule is de novo because relation back is mandatory when the amended claim arises from the conduct alleged in the original complaint. It further held that the hospital-liability claim based on a nurse's removal of the cervical collar arose from the same time, place, subject matter, and injury alleged originally, so the claim related back and was not barred by the statute of limitations. The court affirmed the Court of Appeals and left unresolved whether the claim sounded in professional negligence requiring an expert affidavit.