Sheeley v. Memorial Hospital
Supreme Court of Rhode Island
710 A.2d 161 (1998)
Relevant factsFree
Sheeley (plaintiff) sued family-practice resident Dr. Ryder and Memorial Hospital (defendants) for malpractice during childbirth, but the trial court excluded her expert, a board-certified OB/GYN, because he was not a family practitioner like Ryder, entering a directed verdict for the defendants for lack of expert testimony on the standard of care.
IssueFree
Whether, to testify as to the applicable standard of care in a medical malpractice case, a proposed expert medical witness must practice in the same specialty and within the same or similar locality as the defendant physician.