How has the statute of limitations been interpreted in medical malpractice cases?

The Gopaul court next observed that the basic rationale for application of a liberalized statute of limitations to causes of action for professional malpractice is the inability of the layman to immediately detect the occurrence and results of a professional's failure to measure up to the standards of the profession. (Gopaul v. Herrick Memorial Hosp., supra, 38 Cal.App.3d at pp. 1006-1007, 113 Cal.Rptr. 811.) The court noted that this rationale did not apply to the case before it because "(t)he need to strap plaintiff to the gurney while she was ill and unattended would have been obvious to all" (Id., at p. 1007, 113 Cal.Rptr. at p. 814), and therefore concluded that ordinary rather than professional negligence was involved. However, in a rather puzzling disclaimer, the court stated: "The trial court did not conclude, nor do we, that negligence of a professional person or organization which is obvious to a layman may not be 'professional malpractice.' The test reasonably must be whether the negligence occurred within the scope of the 'skill, prudence, and diligence commonly exercised by practitioners of his profession.' " (Ibid.)