Morrison (plaintiff) went to a nationally certified clinical medical lab in Washington, D.C. for a urethral smear test. The test was administered while Morrison was standing and resulted in Morrison fainting and hitting his head, causing him permanent injuries. Morrison brought a medical malpractice suit against the lab and the technician (defendants), alleging improper administration of the test. Morrison brought expert testimony that the national standard for urethral tests is that they be conducted with the patient in a sitting or lying position. However, the trial court instructed the jury that the defendants should be held to a local standard of care rather than a national one. The jury ruled in favor of the defendants. Morrison appealed.