Arkansas Code Annotated

Ark. Code Ann. § 16-114-202 (2026)

Applicability

✓ current as of May 2026
Find cases: SyfertCases citing this section JustiaArk. Code CornellLII Search CasesGoogle Scholar

This subchapter applies to all causes of action for medical injury accruing after April 2, 1979, and, as to such causes of action, shall supersede any inconsistent provision of law.

History. Acts 1979, No. 709, § 9; A.S.A. 1947, § 34-2620n.

Case Notes

In General.

This subchapter is only applicable to professional services. Sexton v. St. Paul Fire & Marine Ins. Co., 275 Ark. 361, 631 S.W.2d 270 (1982).

Medical Injury.

Section 16-114-201(3) defines “medical injury” sufficiently broadly; claims based on allegations of a failure to provide needed medical care and attention or the timely diagnosis of medical problems come within the ambit of this subchapter and are dependent upon expert testimony as outlined in § 16-114-206(a). Spring Creek Living Ctr. v. Sarrett, 319 Ark. 259, 890 S.W.2d 598 (1995).

Husband's claims against a psychiatrist, a psychologist, and a clinic fell within the purview of the Arkansas Medical Malpractice Act as the claims involved the failure to properly diagnose, assess, and manage his wife's care and treatment. Dodd v. Sparks Reg'l Med. Ctr., 90 Ark. App. 191, 204 S.W.3d 579 (2005).

Summary judgment was properly awarded to a hospital in an action by appellants for negligent credentialing of a surgeon because the Arkansas Medical Malpractice Act did not confer a cause of action for negligent credentialing as a “medical injury”; credentialing decisions did not involve a professional service, a doctor's treatment or order, or a matter of medical science related to specific patient care. Paulino v. QHG of Springdale, Inc., 2012 Ark. 55, 386 S.W.3d 462 (2012).

Negligence.

The trial court erred in treating a medical malpractice claim as an ordinary negligence claim, and in permitting the issues raised by the medical malpractice claim to rest on lay testimony. Spring Creek Living Ctr. v. Sarrett, 319 Ark. 259, 890 S.W.2d 598 (1995).

Res Ipsa Loquitur.

In action under this subchapter, the trial court properly refused the proffered instruction on res ipsa loquitur where all of the essential elements were not present. National Bank of Commerce v. Quirk, 323 Ark. 769, 918 S.W.2d 138 (1996), overruled in part, Ark. Dep't of Health & Human Servs. v. Ahlborn, 547 U.S. 268, 126 S. Ct. 1752, 164 L. Ed. 2d 459 (2006).

Statute of Limitations.

This subchapter's two-year statute superseded the Products Liability three-year statute of limitations to govern plaintiff's product-liability claims brought against a drug company for medical injury as a result of taking the diet drug popularly known as Fen/Phen. Kohl v. American Home Prods. Corp., 78 F. Supp. 2d 885 (W.D. Ark. 1999).

Wrongful Death.

The limitations period provided under this subchapter conflicts with the limitations period provided under the Wrongful Death Act, § 16-62-102; pursuant to this subchapter, § 16-62-102's statute of limitations, as an inconsistent provision of law, is superseded by § 16-114-203's statute of limitations where the two conflict. Hertlein v. St. Paul Fire & Marine Ins. Co., 323 Ark. 283, 914 S.W.2d 303 (1996).

Cited: HCA Health Servs. of Midwest, Inc. v. National Bank, 294 Ark. 525, 745 S.W.2d 120 (1988); Howard v. Northwest Ark. Surgical Clinic, 324 Ark. 375, 921 S.W.2d 596 (1996).

Notes of Decisions
Cited in 19 cases (1 in the last 5 years), 1993–2024 · leading case: Ruffins v. Er Arkansas, Pa, 853 S.W.2d 877 (Ark. 1993).
Ruffins v. Er Arkansas, Pa, 853 S.W.2d 877 (Ark. 1993). · cites it 16× “Ark.Code Ann. § 16-114-202 (1987). An "action for medical injury" is "any action against a medical care provider, whether based in tort, contract, or otherwise, to recover damages on account of medical injury," Ark.”
Morrison v. Jennings, 943 S.W.2d 559 (Ark. 1997). · cites it 8× “" Ark.Code Ann. § 16-114-202 (1987). Under the wrongful death act, the action must be commenced "within three years after the death of the person alleged to have been wrongfully killed.”
Pastchol v. St. Paul Fire & Marine Ins., 929 S.W.2d 713 (Ark. 1996). · cites it 7× “" Ark.Code Ann. § 16-114-202 (1987). It is clear to me that this clause must be read in the context of the Medical Malpractice Act (Ark.”
Adams v. Arthur, 969 S.W.2d 598 (Ark. 1998). · cites it 2× “” Hertlein, supra (quoting Ark. Code Ann. § 16-114-202 (1987)) (emphasis in original).”
Haase v. Starnes, 915 S.W.2d 675 (Ark. 1996). · cites it 2× “§ 16-114-202. Section 16-114-206(a) of the Arkansas Code Annotated provides the party having the burden of proof in " any " action for medical injury " shall " prove that the doctor failed to act in accordance with the degree of skill and learning used by other doctors in the…”
Davis v. Parham, 208 S.W.3d 162 (Ark. 2005). · cites it 2× “” Ark. Code Ann. § 16-114-202 (1987). We have said that the Medical Malpractice Act applies to all causes of action for medical injury arising after April 2, 1979, including wrongful-death and survival actions arising from the death of a patient.”
Dodd v. Sparks Reg'l Med. Ctr., 204 S.W.3d 579 (Ark. Ct. App. 2005). · cites it 2× “Ark. Code Ann. § 16-114-202 . That term is defined in Arkansas Code Annotated section 16-114-201 as: “Medical injury” or “injury” means any adverse consequences arising out of or sustained in the course of the professional services being rendered by a medical care provider,…”
Paulino v. QHG of Springdale, Inc., 386 S.W.3d 462 (Ark. 2012). · cites it 2× “” Ark.Code Ann. § 16-114-202 (Repl.2006); see also Pastchol v.”
Hertlein v. St. Paul Fire & Marine Ins., 914 S.W.2d 303 (Ark. 1996). · cites it 8× “Pursuant to the Medical Malpractice Act, the Wrongful Death Act's statute of limitations, as an inconsistent provision of law, is superseded by the Medical Malpractice Act's statute of limitations.”
Howard v. Nw. Arkansas Surgical Clinic, P.A., 921 S.W.2d 596 (Ark. 1996). · cites it 2× “" A general provision found in § 16-114-202 states that the Medical Malpractice Act "shall supersede any inconsistent provision of law.”
Kohl v. Am. Home Prods. Corp., 78 F. Supp. 2d 885 (W.D. Ark. 1999). · cites it 2× “” Ark.Code Ann. § 16-114-202 (1987) (emphasis added).”
Meredith v. Buchman, 101 F. Supp. 2d 764 (E.D. Ark. 2000). · cites it 4× “” Ark.Code Ann. § 16-114-202. The question presented by the motions for partial summary judgment is whether the Medical Malpractice Act has superseded the damages provision of the Wrongful Death Act in cases where death is caused by medical negligence.”
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.