Smith v. Knowles

Brief Fact Summary. Trustee, Clinton E. Smith (Appellant) commenced a wrongful death action on behalf of his wife and his baby girl. The District Court, Blue Earth County (Minnesota) dismissed his action against Dr. Knowles (Appellee). Appellant sought review of the decision.

Synopsis of Rule of Law. In order for a plaintiff to maintain a medical malpractice action, he or she must introduce testimony as to both the standard of care and the defendant doctor’s departure from that standard. The standard that a physician must exercise is that degree of care, skill, and proficiency exercised by reasonably careful, skillful, and prudent practitioners in the same class to which he belongs, acting under the same or similar circumstances. In order to establish that defendant failed to adhere to this standard, expert testimony is necessary.

Facts. This action was as a result of the deaths of Diane Smith (Smith) and her unborn child. Both died as a result of eclampsia, the full development of eclamptic toxemia, a serious complication of pregnancy when convulsions result from increased blood pressure, albumin in the urine, and the retention of fluid in the patient’s tissues. Appellant testified that his wife had suffered a number of symptoms and had notified Dr. Knowles. Appellant contended that Appellee was negligent in failing to make a timely diagnosis of Smith’s pre-eclampsia, and in treating that condition once it was diagnosed. The parties presented contradicting evidence as to whether Smith had showed symptoms of pre-eclampsia prior to her admission to the hospital in February, 1974. Appellant failed to call independent medial witnesses. He relied on the introduction of excerpts from medical treatises, and the cross-examination of Appellee. The trial court concluded that such evidence was insufficient to meet the b
urden of proof. The Supreme Court of Minnesota affirmed.

Issue. Was the granting of the Motion for Directed Verdict proper?

Held. Yes. The court affirmed the granting of the Motion for Directed Verdict.

Discussion. As the court explained, “[t]o establish a prima facie case in (a medical malpractice action) the plaintiff here must introduce testimony as to both the standard of care and the defendant doctor’s departure from that standard.” Specifically, a physician must exercise that degree of care, skill, and proficiency exercised by reasonably careful, skillful, and prudent practitioners in the same class to which he belongs, acting under the same or similar circumstances. Expert testimony was required in order to establish also that a defendant’s failure to adhere to such a standard was the direct cause of the decedent’s death. Since jurors are not skilled in the practice of medicine, it would be exceedingly difficult for them to evaluate a physician’s degree of skill and his or her adherence to the highest standards of professional care. Absent the introduction of expert medical testimony, the court noted, a jury would be compelled to “speculate as to whether earlier diagnosis or
different treatment would have resulted in a cure.” This the trial court found unacceptable and the appellate court agreed.