Ripes v. Schlechter

Plaintiff filed complaint alleging breach of contract, medical battery, and a violation of the Consumer Fraud Act, after an errant plastic surgery procedure involving removal and replacement of breast implants. Court properly dismissed suit, as Plaintiff was required to, but did not, attach Section 2-622 reviewing physician's affidavit. Plaintiff failed to state cause of action under Consumer Fraud Act, as the wrong alleged is a purely private wrong premised on physician's practice of medicine, and does not affect the public generally. (FITZGERALD SMITH and COBBS, concurring.)