The ill-treated patient has sought redress for medical malpractice by actions that sound in tort, in contract, or in fraud. As with other actions, the underlying policy of "peace and repose" of all statutes of limitations dictates that these actions be timely. In Ohio, for example, the time limit for an action for malpractice is one year.
Ernest A. Cieslinski, Statute of Limitations in Malpractice Actions, 13 Clev.-Marshall L. Rev. 313 (1964)