The Maryland Court of Special Appeals recently rendered a decision in a case, Powell v. Wurm, Md. Ct. Sp. App. (2015), that arose under a medical malpractice cause of action.
The issue fell within the Maryland Health Care Malpractice Claims Act, which requires a plaintiff to file a contemporaneous statement from a qualified expert with the medical malpractice claim.
In the case, the plaintiff, as the personal representative for the estate of the decedent, filed a medical malpractice action and included a certificate of a qualified expert and the report from a medical expert retained by the estate.