The New York Court of Appeals yesterday held that the tort claims notice requirements of Virginia and Maryland govern, under the doctrine of comity, in a New York-filed action on behalf of a woman who may have received infected injections of human growth hormone.

Thursday’s decision in Crair v. The Brookdale Hospital Medical Center, 21, upholds the dismissal of suits lodged against the University of Virginia and the University of Maryland School of Medicine by the estate of Stacey Crair. The Court ruled unanimously that New York courts must enforce notice of claim provisions in Virginia and Maryland law, and therefore barred the action on time grounds.

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