The Indiana Court of Appeals recently ruled in a significant medical malpractice case involving Preston Pratt and his late wife, Wanda Pratt. The court's decision, filed on August 31, 2026, addressed whether Pratt's claims against several healthcare providers were timely under Indiana's Medical Malpractice Act. The ruling affects patients and healthcare providers in Indiana, particularly regarding the statute of limitations for medical malpractice claims.
The case, Preston Pratt v. Anonymous Physician 1, was brought to the court after Pratt alleged that his wife died due to substandard medical care from her physicians. The court determined that Pratt's proposed complaint was timely regarding one physician but not for another, leading to a mixed outcome.
Background
Wanda Pratt was a heavy smoker who was diagnosed with pulmonary nodules in 2013. After several consultations with Pulmonologist, she underwent multiple CT scans, which showed no significant changes in the nodules over the years. In March 2018, Pulmonologist advised her that further scans were unnecessary due to the stability of the nodules. Unfortunately, Wanda did not return for follow-up care as instructed.
In May 2022, Wanda sought emergency care in Alabama, where she was diagnosed with stage IV lung cancer. She passed away in September 2023. Following her death, Preston Pratt filed a proposed complaint against Pulmonologist, Family Doctor, and other healthcare entities, claiming that their negligence contributed to Wanda's death. The case was initially filed in the Tippecanoe Circuit Court.
The Ruling
The Indiana Court of Appeals, led by Judge Mathias, ruled on the summary judgment motions filed by the defendants. The court affirmed the trial court's decision in part but reversed and remanded it in part for further proceedings. The court found that Pratt's claims against Pulmonologist were timely under the Martin/Van Dusen exception to Indiana's two-year statute of limitations for medical malpractice cases.
The court stated, "Pratt’s proposed complaint filed on March 13, 2024, was timely under the Martin/Van Dusen exception to Indiana Code section 34-18-7-1(b), and we reverse the trial court’s entry of summary judgment for Pulmonologist, the Hospital, and the Facility."
However, the court upheld the trial court's summary judgment for Family Doctor, concluding that Pratt's claims against him were not timely. The court noted that Family Doctor's treatment did not relate to Wanda's pulmonary nodules or cancer screening.
Impact
This ruling has significant implications for medical malpractice claims in Indiana. It clarifies how the Martin/Van Dusen exception applies to cases where a patient is unaware of a physician's negligence until a later diagnosis of a serious condition, such as cancer. The decision emphasizes that patients may have more time to file claims if they can demonstrate that they were not aware of the malpractice due to the nature of their medical condition.
Additionally, the court's ruling reinforces the importance of follow-up care and the responsibility of patients to seek further medical advice if they have ongoing concerns about their health. This case sets a precedent for similar claims in the future, potentially allowing more patients to pursue justice for alleged medical negligence.
What's Next
Following this ruling, the case will return to the lower court for further proceedings regarding the claims against Pulmonologist and the other healthcare providers involved. It remains to be seen if the defendants will pursue any further appeals or if there are related cases pending.