Published by Arfaa Law Group
In Maryland, incarcerated individuals who receive substandard medical care may have legal recourse against healthcare providers under state medical malpractice laws. However, such cases often involve complex procedural hurdles, including compliance with the state’s medical malpractice filing requirements and statutory limitations. A recent decision from a Maryland court highlights these challenges while also demonstrating that the courts will aim to protect a plaintiff’s right to pursue medical negligence claims. If you sustained injuries due to inadequate medical care, it is advisable to meet with a Baltimore medical malpractice attorney as soon as possible.
Facts and Procedure of the Case
It is reported that the plaintiff filed a lawsuit against two healthcare providers contracted to deliver medical services at the federal facility where he was housed. The plaintiff alleged that both entities failed to diagnose and treat his multiple sclerosis (MS) in a timely manner, causing him prolonged suffering and exacerbation of his condition. He contended that his repeated complaints about symptoms were ignored and that necessary diagnostic testing was not performed.
It is alleged that the plaintiff initially filed an amended complaint asserting claims under the Eighth Amendment and Maryland’s Declaration of Rights, as well as a claim under precedent that allows lawsuits against government entities for unconstitutional policies. However, the court dismissed the constitutional claims, leaving only the claim against the healthcare providers. The plaintiff later sought to file a second amended complaint to add medical malpractice claims under Maryland law, contending that the providers negligently failed to diagnose and treat his MS.
The defendant healthcare provider opposed the plaintiff’s motion to amend, arguing that the proposed claims were barred by Maryland’s statute of limitations for medical malpractice actions, which generally requires that a claim be filed within five years of the alleged injury or within three years of when the injury was discovered. The defendant asserted that because its contract to provide medical services at the prison ended in 2018, the plaintiff’s claims—filed in 2024—were untimely.
The plaintiff countered that his claims were still viable under the statutory fraud-discovery exception, arguing that the defendants’ failure to diagnose his MS in a timely manner effectively prevented him from discovering his injury. He alleged that the healthcare providers’ systemic practice of ignoring inmates’ medical concerns and avoiding diagnostic testing delayed his awareness of his condition until he was officially diagnosed in 2021.
Timeliness of Medical Malpractice Claims
The district court evaluated whether the plaintiff’s proposed medical malpractice claims were legally viable or if they were barred by the statute of limitations. Under Maryland law, medical malpractice claims must be brought within either: five years from the date the alleged negligence occurred, or three years from the date the injury was discovered, whichever is earlier.
The court noted that while the defendant’s contract ended in 2018, the plaintiff was not diagnosed with MS until 2021. If the plaintiff’s allegations were true—that the defendants actively avoided diagnosing his condition—then his injury may not have been “discovered” until much later. Given the uncertainty surrounding when the plaintiff could have reasonably known of his injury, the court declined to dismiss the claim at this stage.
Additionally, Maryland law requires medical malpractice plaintiffs to first file their claims with the Healthcare Alternative Dispute Resolution Office (HCADRO) before proceeding in court. The plaintiff had complied with this requirement, and the case was transferred to federal court from HCADRO, further supporting the legitimacy of the malpractice claims.
Because the court could not definitively determine whether the statute of limitations had expired without further factual development, it granted the plaintiff’s motion to amend his complaint. The court emphasized the importance of resolving cases on their merits rather than on procedural technicalities and ruled that the plaintiff should be allowed to proceed with his medical malpractice claims.
Meet with an Experienced Baltimore Medical Malpractice Attorney
If you suffered losses due to medical negligence, you may be entitled to compensation, and it is smart to talk to an attorney. At Arfaa Law Group, our experienced Baltimore medical malpractice attorneys dedicate their practice to holding negligent healthcare providers accountable, and if we represent you, we will work tirelessly on your behalf. Call us today at (410) 889-1850 or complete our online form to schedule a consultation and discuss your legal options.