Sheeley v. Memorial Hospital – Case Brief
Sheeley v. Memorial Hospital, 710 A.2d 161 (R.I. 1998).
Facts: Sheeley (P) gave birth and received an episiotomy. Sheeley developed complications and sued the physician and Memorial Hospital (D). P sought to introduce the testimony of an expert witness to establish the standard of care and D objected on the grounds that an expert witness must be in the same field as the defendant physician. The trial court sustained and entered a directed verdict in favor of D. P appealed.
Issue: 1) What are the criteria for determining whether an expert witness is qualified to testify regarding the standard of care in the medical field? 2) Is the appropriate standard of care regarding cases in the medical field based on the standard of reasonable care in the same or similar locality, or on a national standard?
Holding and Rule: 1) Any doctor with knowledge of the procedure acquired through experience, observation, association, or education is competent to testify about the requisite standard of care. In deciding whether to qualify an expert the court should consider a physician’s resources, practice area, and experience, but no one issue should be determinative. 2) The appropriate standard of care regarding cases in the medical field is based on a national standard of reasonable care.
Policy: The “same or similar locality” rule has come under attack because it legitimizes a low standard of care in smaller communities; furthermore the standard failed to address the conspiracy of silence that has prevented plaintiffs from obtaining expert testimony. The old standard is no longer applicable in view of the present day realities of the medical profession and modern transportation and communication.
Disposition: For P.