James B. York


This Note addresses the importance of the Missouri Supreme Court’s decision in Montgomery v. South County Radiologists, Inc., and its future effect on the continuing care exception and its development throughout Missouri jurisprudence. This Note then reviews the majority’s decision in Montgomery and argues that the Missouri Supreme Court inappropriately extended the scope of the exception. Finally, this Note suggest that the interpretation of the continuing care exception used by the majority in Montgomery offers no guidance for providers of auxiliary medical services, which will result in an overall increase in the cost of health care and result in the application of the exception in more cases than the Missouri statute of limitation, effectually transforming the exception into the rule.

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