Case Involving Alleged Omission of Lab Results from An Autopsy Report by Pathologist
In Milos v. Hall, 325 Ill. App. 3d 180, 184, 757 N.E.2d 654, 258 Ill. Dec. 965 (2001), the Court held that a section 2-622 certificate was not required where a plaintiff alleges that a pathologist wilfully and maliciously omitted certain premortem lab results from an autopsy report in order to misrepresent the cause of death for the purpose of protecting other doctors from liability claims. Milos, 325 Ill. App. 3d at 184.
The Milos court found that the plaintiff did not allege that the pathologist breached an accepted standard of care while attempting to restore the deceased to normal mental or physical health.