Canton Harbor Healthcare v. Robinson

Summary

The Supreme Court of Maryland held that a registered nurse may sign a health-care malpractice certificate stating that breaches of nursing standards proximately caused a previously diagnosed pressure ulcer at a skilled nursing facility, so long as the nurse satisfies the statutory peer-to-peer requirement and does not offer a medical-causation diagnosis. The nurse may testify regarding nursing breaches but may not attest to standards applicable to physicians or physician departures from those standards. Because the certificate adequately supported the negligence claim, the court affirmed the appellate judgment allowing that claim to proceed.