Cornerstone Hosp. of Se. Ariz., L.L.C. v. Marner
In Cornerstone Hosp. of Se. Ariz., L.L.C. v. Marner, 231 Ariz. 67, 290 P.3d 460 (App. 2012), the Court found, as a matter of first impression, that statutes governing expert witness qualifications in MMA actions apply equally to APSA claims based on medical negligence. See id.7, 14.
The court concluded the plaintiff in Cornerstone had alleged medical malpractice in his complaint under 12-561(2), even though the complaint purported to bring an action solely under the APSA. Id.2, 21. The fact that claims of medical negligence and malpractice "involve a vulnerable adult and may be brought under APSA does not change their nature." Id.21.