AOM requirement (Michigan) · Go Syfert
← Michigan issues

AOM requirement in Michigan

8 Michigan opinions name it 2 courts 2015–2023 2 in the last five years

The cases below were cited by Michigan courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (7)

CaseFollowedCited
Gebhardt v. O'ROURKEgreen
mich · 1994 · cited in 2 Michigan opinions naming this issue, 2017–2017
2 sentences

2017Contrary to the dissent’s suggestion below, Tyra did not involve the AOM requirement, but rather the notice of intent (NOI) requirement in § 2912b(1); thus any mention of the AOM requirement in Tyra was clearly dicta. 15 Gebhardt v O’Rourke, 444 Mich 535, 542-543 (1994).

2017Contrary to the dissent’s suggestion below, Tyra did not involve the AOM requirement, but rather the notice of intent (NOI) requirement in § 2912b(1); thus any mention of the AOM requirement in Tyra was clearly dicta. 15 Gebhardt v O’Rourke, 444 Mich 535, 542-543 (1994).

22
Radlax Gateway Hotel, LLC v. Amalgamated Bankgreen
scotus · 2012 · cited in 2 Michigan opinions naming this issue, 2017–2017
2 sentences

2017However, “[i]n order to determine which provision is truly more specific and, hence, controlling, we consider which provision applies to the more narrow realm of circumstances, and which to the more broad realm.” Miller v Allstate Ins Co, 481 Mich 601, 613 (2008). 16 RadLAX Gateway Hotel, LLC v Amalgamated Bank, 566 US 639, 645 (2012); Detroit Edison Co v Dep’t of Treasury, 498 Mich 28, 43-44 (2015); Scalia & Garner, Reading Law: The Interpretation of Legal Texts (St Paul: Thomson/West, 2012), p 183. 4 to provide medical opinion evidence that their claims are not frivolous—and it need not take

2017However, “[i]n order to determine which provision is truly more specific and, hence, controlling, we consider which provision applies to the more narrow realm of circumstances, and which to the more broad realm.” Miller v Allstate Ins Co, 481 Mich 601, 613 (2008). 16 RadLAX Gateway Hotel, LLC v Amalgamated Bank, 566 US 639, 645 (2012); Detroit Edison Co v Dep’t of Treasury, 498 Mich 28, 43-44 (2015); Scalia & Garner, Reading Law: The Interpretation of Legal Texts (St Paul: Thomson/West, 2012), p 183. 4 to provide medical opinion evidence that their claims are not frivolous—and it need not take

22
William Miller v. Allstate Ins Cogreen
mich · 2008 · cited in 2 Michigan opinions naming this issue, 2017–2017
2 sentences

2017However, “[i]n order to determine which provision is truly more specific and, hence, controlling, we consider which provision applies to the more narrow realm of circumstances, and which to the more broad realm.” Miller v Allstate Ins Co, 481 Mich 601, 613 (2008). 16 RadLAX Gateway Hotel, LLC v Amalgamated Bank, 566 US 639, 645 (2012); Detroit Edison Co v Dep’t of Treasury, 498 Mich 28, 43-44 (2015); Scalia & Garner, Reading Law: The Interpretation of Legal Texts (St Paul: Thomson/West, 2012), p 183. 4 to provide medical opinion evidence that their claims are not frivolous—and it need not take

2017However, “[i]n order to determine which provision is truly more specific and, hence, controlling, we consider which provision applies to the more narrow realm of circumstances, and which to the more broad realm.” Miller v Allstate Ins Co, 481 Mich 601, 613 (2008). 16 RadLAX Gateway Hotel, LLC v Amalgamated Bank, 566 US 639, 645 (2012); Detroit Edison Co v Dep’t of Treasury, 498 Mich 28, 43-44 (2015); Scalia & Garner, Reading Law: The Interpretation of Legal Texts (St Paul: Thomson/West, 2012), p 183. 4 to provide medical opinion evidence that their claims are not frivolous—and it need not take

22
Detroit Edison Company v. Department of Treasurygreen
mich · 2015 · cited in 2 Michigan opinions naming this issue, 2017–2017
2 sentences

2017However, “[i]n order to determine which provision is truly more specific and, hence, controlling, we consider which provision applies to the more narrow realm of circumstances, and which to the more broad realm.” Miller v Allstate Ins Co, 481 Mich 601, 613 (2008). 16 RadLAX Gateway Hotel, LLC v Amalgamated Bank, 566 US 639, 645 (2012); Detroit Edison Co v Dep’t of Treasury, 498 Mich 28, 43-44 (2015); Scalia & Garner, Reading Law: The Interpretation of Legal Texts (St Paul: Thomson/West, 2012), p 183. 4 to provide medical opinion evidence that their claims are not frivolous—and it need not take

2017However, “[i]n order to determine which provision is truly more specific and, hence, controlling, we consider which provision applies to the more narrow realm of circumstances, and which to the more broad realm.” Miller v Allstate Ins Co, 481 Mich 601, 613 (2008). 16 RadLAX Gateway Hotel, LLC v Amalgamated Bank, 566 US 639, 645 (2012); Detroit Edison Co v Dep’t of Treasury, 498 Mich 28, 43-44 (2015); Scalia & Garner, Reading Law: The Interpretation of Legal Texts (St Paul: Thomson/West, 2012), p 183. 4 to provide medical opinion evidence that their claims are not frivolous—and it need not take

22
Young v. Sellersgreen
michctapp · 2003 · cited in 1 Michigan opinions naming this issue, 2023–2023
1 sentence

2023Id. at 448, 452 .

11
Cox v. Eric J. Hartman, M.D., & Blue Water Obstetrics & Gynecology Prof'l Corp.green
michctapp · 2017 · cited in 1 Michigan opinions naming this issue, 2019–2019
2 sentences

2019See also Cox v Hartman, 322 Mich App 292 ; 911 NW2d 219 (2017) (distinguishing between a nurse practitioner and a registered nurse); Decker v Flood, 248 Mich App 75, 79, 83-84 ; 638 NW2d 163 (2001) (holding that a dentist who routinely performed root canals and was a “ ‘doctor of dental surgery’ . . . [as well as] a member of the American Association of Endodontists,” was not qualified to offer expert testimony or provide an AOM on the standard of practice applicable to a general practitioner dentist who was allegedly negligent when he performed a root canal).

2019See also Cox v Hartman, 322 Mich App 292 ; 911 NW2d 219 (2017) (distinguishing between a nurse practitioner and a registered nurse); Decker v Flood, 248 Mich App 75, 79, 83-84 ; 638 NW2d 163 (2001) (holding that a dentist who routinely performed root canals and was a “ ‘doctor of dental surgery’ . . . [as well as] a member of the American Association of Endodontists,” was not qualified to offer expert testimony or provide an AOM on the standard of practice applicable to a general practitioner dentist who was allegedly negligent when he performed a root canal).

11
Decker v. Floodgreen
michctapp · 2002 · cited in 1 Michigan opinions naming this issue, 2019–2019
2 sentences

2019See also Cox v Hartman, 322 Mich App 292 ; 911 NW2d 219 (2017) (distinguishing between a nurse practitioner and a registered nurse); Decker v Flood, 248 Mich App 75, 79, 83-84 ; 638 NW2d 163 (2001) (holding that a dentist who routinely performed root canals and was a “ ‘doctor of dental surgery’ . . . [as well as] a member of the American Association of Endodontists,” was not qualified to offer expert testimony or provide an AOM on the standard of practice applicable to a general practitioner dentist who was allegedly negligent when he performed a root canal).

2019See also Cox v Hartman, 322 Mich App 292 ; 911 NW2d 219 (2017) (distinguishing between a nurse practitioner and a registered nurse); Decker v Flood, 248 Mich App 75, 79, 83-84 ; 638 NW2d 163 (2001) (holding that a dentist who routinely performed root canals and was a “ ‘doctor of dental surgery’ . . . [as well as] a member of the American Association of Endodontists,” was not qualified to offer expert testimony or provide an AOM on the standard of practice applicable to a general practitioner dentist who was allegedly negligent when he performed a root canal).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Michigan. Read the followed side critically anyway.

Also cited on this issue (3)

CaseCitedYears
VandenBerg v. VandenBerg green
michctapp · 1998
2 sentences

2015VandenBerg v VandenBerg, 231 Mich App 497, 502 ; 586 NW2d 570 (1998).

2015VandenBerg v VandenBerg, 231 Mich App 497, 502 ; 586 NW2d 570 (1998).

22015–2015
King v. Reed green
michctapp · 2008
2 sentences

2023In King v Reed, 278 Mich App 504 ; 751 NW2d 525 (2008), the Court of Appeals addressed the AOM requirement of MCL 600.2912d.

2023In King v Reed, 278 Mich App 504 ; 751 NW2d 525 (2008), the Court of Appeals addressed the AOM requirement of MCL 600.2912d.

12023–2023
Scarsella v. Pollak green
mich · 2000
1 sentence

2020In Scarsella, the Court examined the MCL 600.2912d(1) requirement that a medical malpractice plaintiff “shall file with the complaint an [AOM] signed by a health professional . . . .” Limiting our holding to the AOM requirement in that statute, we held that the plaintiff’s failure to file the affidavit rendered the complaint “ineffective,” in that it would “not work a tolling of the applicable period of limitation.” Scarsella 461 Mich at 553 .

12020–2020

Statutes the citing opinions construe

MI § Mich. Comp. Laws § 600.2912d (8) MI § Mich. Comp. Laws § 600.5856 (7) MI § Mich. Comp. Laws § 600.2912b (5) MI § Mich. Comp. Laws § 600.5805 (5) MI § Mich. Comp. Laws § 600.101 (4) MI § Mich. Comp. Laws § 600.1901 (3) MI § Mich. Comp. Laws § 600.5838a (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

NJ 21 (2016–2026) MI 8 (2015–2023)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

← Caselaw search · G Cite Topics · Brief Check