Sheeley v. Memorial Hospital

Brief Fact Summary.

Sheeley (Plaintiff) sued Memorial Hospital (Defendant) and a family practice resident for medical malpractice. The trial court did not allow Plaintiff’s expert witness, a board-certified obstetrician/gynecologist to testify on the applicable standard of care because he was not a family practice doctor.

Synopsis of Rule of Law.

A physician must exercise the degree of caution and skill expected of a reasonably competent practitioner in the same class, acting in the same or similar circumstances.

Facts.

Plaintiff was injured from an episiotomy performed by a second-year family practice resident at Defendant hospital. Plaintiff sued both the doctor and the hospital, alleging medical malpractice. At trial, Plaintiff sought to introduce the testimony of a board-certified obstetrician/gynecologist to explain the applicable standard of care. The trial court did not allow Plaintiff’s expert witness to testify because he was not in family practice. Defendant moved for a directed verdict, which was granted. Plaintiff appealed, arguing that the court excluded the expert testimony in error. Plaintiff replied that the expert was properly excluded because he did not have direct knowledge of the applicable standard of care for a family practice resident providing obstetric care in Rhode Island, or a similar locality.

Issue.

Is the applicable standard of care for a physician the degree of caution and skill expected of a reasonably competent practitioner in the same class, acting in the same or similar circumstances?

Held.

(Goldberg, J.) Yes. A physician must exercise the degree of caution and skill expected of a reasonably competent practitioner in the same class, acting in the same or similar circumstances. The traditional locality rules no longer fit the modern medical malpractice cases. The new standard is a national one. Even though he has a different specialty than the defendant, so long as the expert has the required knowledge, skill, experience, training, or education in the field of the alleged malpractice, he may serve as a witness. In most cases, a physician who is board-certified in a specialty should be presumptively qualified to give an opinion in a malpractice case. Reversed and remanded.

Discussion.

The court here adopted a new, national standard for medical malpractice cases. Many states now follow this approach as well. Even the states that have not adopted a national standard, hold physicians in a certain specialty to the same standard of care as all physicians in that specialty.