In February 1994, Janet Warren filed suit against Shands for medical malpractice. Under court rules, a copy of the complaint had to be served on Shands within 120 days of filing. Here, it was served on the 121st day. The trial court ultimately dismissed the suit because of the violation, but the First District reversed so the trial court could consider certain standards that might excuse the late service. In its appeal, Shands argues that the standards used by the First District are incorrect.