Before we address these questions, a brief review of the law’s development in this area is appropriate. The Evolution of Negligence Claims in the Medical Setting Under traditional legal principles, our courts recognized that not every negligence action asserted against a hospital or doctor was one for medical malpractice. Estate of Doe v. Vanderbilt Univ., Inc., 958 S.W.2d 117, 120 (Tenn.Ct.App.1997). Indeed, the courts recognized that some claims against medical providers sounded only in ordinary negligence. Drawing this distinction had several important consequences. For example, although medical malpractice claims typically required expert proof, claims asserting ordinary negligence did not. See, e.g., Peete v. Shelby Cnty. Health Care Corp., 938 S.W.2d 693, 696 (Tenn.Ct.App.1996) (<HOLDING>). In addition, distinguishing a medical
holding that expert testimony is not required to corroborate a claim for emotional distress holding that proof of an explicit agreement is not required holding that ordinary negligence and gross negligence are not separate causes of action holding that expert proof was not required for an asserted claim of ordinary negligence holding that a negligence claim is not a personal injury tort claim