When the Legislature took up tort reform in the 1980s, one of the requirements they imposed on medical malpractice actions was that a certificate of merit be filed along with the complaint. It essentially requires an attorney bringing a malpractice action to certify, based upon a consultation with a physician, that the claim has merit. Although it is a fairly simple procedure, it has occasionally necessitated litigation over the impact of a failure to so certify, as well as the nature of the certification required in certain types of cases. Thirty-seven years after the passage of this requirement, the courts continue to grapple with these questions. In this column, we review the evolution of those decisions. First, however, it is appropriate to describe the pertinent statutory provisions.