2 Year Statute of Limitations for ''Health Care'' Liability Claims In Texas

Section 10.01 of article 4590i provides for a strict 2-year statute of limitations for all health care liability claims. TEX. REV. CIV. STAT. ANN. art. 4590i, 10.01. A health care provider is "any person, partnership, professional association, corporation, facility, or institution duly licensed or chartered by the State of Texas to provide health care as a registered nurse, hospital, dentist, podiatrist, pharmacist, or nursing home, or an officer, employee, or agent thereof acting in the course and scope of his employment." Id. 1.03(3). This definition includes only those persons or entities specifically listed and does not impliedly include other entities. See, e.g., Townsend v. Catalina Ambulance Co., 857 S.W.2d 791, 796 (Tex. App.--Corpus Christi 1993, no writ). A cause of action for personal injury under section 16.003 of the civil practice and remedies code must be brought within 2 years from the date the cause of action accrues. Id.; Childs v. Haussecker, 974 S.W.2d 31, 36 (Tex. 1998). A cause of action accrues when a wrongful act causes an injury. See Childs, 974 S.W.2d at 36; S.V. v. R.V., 933 S.W.2d 1, 4 (Tex. 1996).