Jodine Williams, et al. v. Athletico, Ltd., et al.

The Cray Huber appellate department persuaded the First District Appellate Court to answer a certified question in the affirmative and to rule that the plaintiffs were required to attach to their complaint an affidavit and health professional’s report pursuant to section 2-622 of the Code of Civil Procedure.  The complaint alleged negligent conduct by a licensed athletic trainer hired to provide on-site injury evaluation and treatment to participants in a high school football game for failing to assess and evaluate a participating athlete for a concussion.  The appellate court ruled that the allegations of the complaint clearly implicated medical judgment, and such determinations could only be properly made by an individual with the necessary training and expertise.