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Sheeley v. Memorial Hospital

(1998)

Supreme Court of Rhode Island - 710 A.2d 161

tl;dr:

A procedure by a medical resident goes wrong and Plaintiff hires an expert to testify at trial; Court finds that expert is qualified to testify because he is knowledgeable of the specific procedure.

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Facts & HoldingSheeley v. Memorial Hospital case brief facts & holding

Facts:Plaintiff gives birth, and Defendant doctor, a second-year resident, performs...

Holding:The Rhode Island Supreme Court remanded.The Defendant argued:Plaintiff's expert has...

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Sheeley v. Memorial Hospital | Case Brief DeepDive
Majority opinion, author: GOLDBERG, Justice.
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The court found that the trial justice made an error in excluding the testimony of an expert witness in a medical malpractice case. The court clarified that an expert witness does not need to practice in the same specialty as the defendant physician, as long as they have the necessary knowledge, skill, experience, training, or education in the field of the alleged malpractice. The court abandoned the "similar locality" rule and held that any doctor with knowledge or familiarity with the procedure is competent to testify concerning the requisite standard of care and whether the care in any given case deviated from that standard. The case is remanded for a new trial, and the trial justice should consider various factors in determining the qualification of an expert witness, but no one issue should be determinative.

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Sheeley v. Memorial Hospital

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