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Sheeley v. Memorial Hospital

Supreme Court of Rhode Island
710 A.2d 161 (R.I. 1998)



Sheeley (plaintiff) gave birth at Memorial Hospital (defendant). During the birth, Dr. Ryder (defendant), a family practice resident, performed a procedure that later caused complications. Sheeley brought an action for medical malpractice. Rhode Island law limits expert testimony to someone who is qualified based on knowledge, skill, experience, training or education. At trial, the court excluded the testimony of Sheeley’s expert witness, Dr. Leslie, who would have testified as to the alleged malpractice and the applicable standard of care. The trial court relied on the fact that Dr. Leslie is a board certified obstetrician/gynecologist (OB/GYN), and not a family practitioner, like Dr. Ryder. Without such expert testimony from the plaintiff, the trial court entered a directed verdict for the hospital and Dr. Ryder.

Rule of Law


Holding and Reasoning (Goldberg, J.)

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