Over the past two years, this column has discussed two topics that were subsequently the subject of decisions by the Court of Appeals. Given the importance of all declarations by the highest court of the state on issues related to medical malpractice, this month’s column examines those decisions.
In June of last year, this column addressed long-arm jurisdiction over out-of-state defendants in medical malpractice actions.1 It included a discussion of a 3-2 decision by the Second Department, which found that New York had no jurisdiction over a Florida surgical institute.2 That result was recently affirmed by the Court of Appeals in a unanimous opinion in Paterno v. Laser Spine Institute, ___ N.Y.3d ___, 2014 WL 6473661 (2014), and it has substantial significance for attempts to premise jurisdiction on Internet and other electronic contacts between out-of-state health care providers and New York residents.
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