Sheeley v. Memorial Hospital

Rhode Island Supreme Court · Torts

TortsMedical MalpracticeExpert TestimonyStandard of Caremedical malpracticeexpert witnessstandard of caresimilar locality rule

Facts

After giving birth at Memorial Hospital in 1987, Sheeley developed complications from an episiotomy and later a rectovaginal fistula requiring corrective surgery. She sued the hospital, Dr. Ryder, and Dr. Jack, alleging negligence in performing the episiotomy and repairing it. At trial, she offered Dr. Stanley Leslie, a board-certified obstetrician/gynecologist, to testify about the applicable standard of care and Dr. Ryder's alleged malpractice. The trial justice excluded his testimony on the view that he was not in the same medical field as a family practice resident, and because Sheeley had no other expert, the court granted a directed verdict for defendants.

Issue

Whether the trial justice erred in excluding the testimony of a board-certified OB/GYN offered against a family practice resident performing obstetric care. The case also presented whether Rhode Island should continue to apply the similar locality rule in defining the medical malpractice standard of care.

Rule

In a medical malpractice case, the focus is the procedure performed and whether it was executed in conformity with the recognized standard of care, not the defendant physician's specialty label. Any doctor with knowledge of or familiarity with the procedure, acquired through experience, observation, association, or education, is competent to testify about the standard of care and deviation from it. Except in extreme cases, a witness with board certification in a specialty related to the procedure in question should be presumptively qualified. Rhode Island abandons the similar locality rule and adopts a national standard: a physician must use the degree of care and skill expected of a reasonably competent practitioner in the same class, acting in the same or similar circumstances.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

At a hospital in Providence, Dr. Nina Corbett, an internal medicine resident, inserted a central venous catheter during emergency treatment. The patient later sued, offering Dr. Evan Morales, a board-certified anesthesiologist from Boston who regularly teaches and supervises central-line placement, to testify that the insertion technique fell below the standard of care.

Should the court exclude Dr. Morales solely because he is not an internal medicine physician?

Explanation. The majority held that expert qualification turns on knowledge, skill, experience, training, or education in the field of the alleged malpractice, and that the focus should be the procedure performed rather than the defendant's specialty. A doctor familiar with the procedure may testify even without sharing the defendant's specialty. The identical-specialty requirement was rejected.