Illinois Appeals Panel Answers Certified Question Regarding Claim Splitting

ELGIN, Ill. – An Illinois appeals panel on July 22 answered a certified question posed in a refiled medical malpractice action, concluding that “apparent and actual agency are separate claims subject to the bar of res judicata and the prohibition against claim splitting” (Brandon Wilson, et al. v. Edward Hospital, No. 2-11-0085, Ill. App., 2nd Dist.; 2011 Ill. App. Unpub. LEXIS 1722).
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