A state law extending the time to amend a medical malpractice lawsuit applies to both newly discovered and newly identified defendants, the Supreme Court of Ohio ruled today.

In a unanimous opinion, the Supreme Court affirmed a Fifth District Court of Appeals decision allowing a plaintiff, Christine Lewis, who was injured when she fell out of a bed at Mansfield Hospital, to add a physician and his employer to her lawsuit 14 months after the incident. The Richland County Common Pleas Court had ruled that Lewis had waited too long and could not add the physician group past the 12-month statute of limitations for medical claims.

Writing for the Court, Justice Patrick F. Fischer explained that R.C. 2323.451 provides a 180-day extension to name “additional” defendants who were not included or named in the original complaint. This includes those whom Lewis may have contemplated when filing her original complaint, but whose identity she did not know.

The decision allowed Lewis to add Anand Patel and his employer, Mid-Ohio Emergency Physicians, to the lawsuit against MedCentral Health System, which does business as OhioHealth Mansfield Hospital.

Patient Sues After Fall, Fractures Neck
In February 2022, Lewis was a patient at Mansfield Hospital. She alleged that she was left unattended while medicated and fell out of her hospital bed, fracturing her neck.

She filed a negligence lawsuit against Mansfield Hospital in October 2022. She also named 10 other defendants by the fictitious name of “John Doe.” Her original complaint filed in the Richland County Common Pleas Court identified the 10 as “physicians, nurses, hospitals, corporations, health care professionals, or other entities that provided negligent medical or health care individually or through their employees and/or agents” to Lewis the day she was injured.

The complaint was sent to Mansfield Hospital by certified mail, and the hospital filed its answer a month later, denying liability. Lewis did not attempt to serve any of the other defendants with her complaint.

In April 2023, 14 months after the injury occurred, Lewis received the hospital’s consent to amend her complaint and add the names of the John Doe defendants. Her amended complaint included Patel and his employer, Mid-Ohio Emergency Physicians. She also added four other defendants.

Patel and Mid-Ohio moved the court to dismiss them from the lawsuit, arguing that Lewis failed to name them within the one-year statute of limitations for medical claims. They also argued Lewis did not comply with the requirements of Rule 15(D) of the Ohio Rules of Civil Procedure for naming and serving unknown defendants. Lewis argued that under R.C. 2323.451, she had an additional 180 days after the one-year deadline to add defendants.

The trial court dismissed Patel and Mid-Ohio, ruling that R.C. 2323.451 did not give Lewis time after the deadline to add new defendants who “were obvious when the case began.” The trial court ruled she could not use the name “John Doe” as a placeholder to extend her time past the one-year deadline to provide their actual names and serve them with copies of the lawsuit.

Lewis appealed to the Fifth District, which reversed the trial court’s decision. Patel and Mid-Ohio appealed the decision to the Supreme Court. No other defendants in the case appealed.

Supreme Court Analyzed Law and Civil Rule
The Court had to address two issues to resolve the case. The physician group claimed that R.C. 2323.451 applies only to newly discovered defendants whose role in the accident was not known at the time the lawsuit was filed. They also argued that Lewis still had to abide by Rule 15(D), requiring her to identify Patel and Mid-Ohio within the one-year statute of limitations.

The opinion explained that Rule 15(D) cannot be used to extend the statute of limitations, but has “the limited purpose of accommodating a plaintiff who has identified an allegedly culpable party but does not know the name of the party at the time of filing a complaint.” The rule allows a plaintiff to serve an unknown defendant and later amend the complaint to name the person being sued.

The Court noted that compliance with Ohio’s one-year statute of limitations for medical claims is challenging. A patient often receives medical care from several providers and entities that may or may not operate under their legal name. The Court explained that “the plaintiff may have trouble determining the names of every defendant to include in a complaint and commencing an action against each defendant before the statute of limitations expires.”

To meet the deadline and Rule 15(D), plaintiffs previously used a “shotgun approach,” the Court explained, suing numerous potential defendants and then subsequently dismissing unnecessary defendants as discovery proceeded.

The opinion explained that lawmakers enacted R.C. 2323.451 to minimize the shotgun approach. Under R.C. 2323.451, the “parties may seek to discover the existence or identity of any other potential medical claims or defendants that are not included or named in the complaint” and may add additional defendants up to 180 days after the one-year statute of limitations. The law also requires that all parties comply with Rule 15, but does not indicate which part of Rule 15 applies.

While the doctors argued Lewis needed to comply with Rule 15(D), the Court disagreed. That provision applies in cases where the plaintiff knows the identity and whereabouts of a defendant, but not the actual name of the defendant.

Rule 15(D) did not apply because Lewis did not identify Patel or Mid-Ohio in her original complaint, and was not amending her complaint to name previously included defendants. Instead, she was naming “additional defendants” under R.C. 2323.451(D)(2), which allows the addition of parties whose names or identities were unknown at the time the original complaint was filed.

Since Patel and Mid-Ohio were not defendants in the original complaint, they can be added under R.C. 2323.451. Because Lewis fulfilled all the other requirements of the law to name them, the Court affirmed the decision to add them to her case.

2024-0451. Lewis v. MedCentral Health Sys., Slip Opinion No. 2025-Ohio-4802.

View oral argument video of this case.

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