Sheeley v. Memorial Hospital
710 A.2d 161 (1998)
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Rule of Law:
In a medical malpractice action, the standard of care is a national one, requiring a physician to use the degree of care and skill expected of a reasonably competent practitioner in the same class acting in similar circumstances. The 'similar locality' rule is abandoned, and an expert witness is qualified if they have sufficient knowledge, skill, or experience regarding the specific procedure at issue, regardless of their specialty or geographic location.
Facts:
- On May 19, 1987, Joanne Sheeley gave birth to a child at Memorial Hospital under the care of Dr. Mary Ryder, a second-year family practice resident.
- Dr. Ryder was supervised by Dr. Brian Jack, a faculty member.
- During the delivery, Dr. Ryder performed an episiotomy on Sheeley, which is a surgical incision into the perineum.
- After the delivery, Dr. Ryder repaired the episiotomy incision by stitching it.
- Following her discharge from the hospital, Sheeley developed a rectovaginal fistula, an opening between her vagina and rectum, in the area of the episiotomy.
- Sheeley required corrective surgery to repair the fistula and continued to suffer from pain and discomfort.
Procedural Posture:
- Joanne Sheeley and her husband sued Dr. Mary Ryder, Dr. Brian Jack, and Memorial Hospital in the Rhode Island Superior Court for medical malpractice.
- During the trial, the defendants filed a motion in limine to exclude the expert testimony of Sheeley's witness, Dr. Stanley Leslie.
- The trial justice granted the defendants' motion to exclude the testimony.
- As Sheeley had no other expert, the trial justice then granted the defendants' motion for a directed verdict, ending the case in the defendants' favor.
- Joanne Sheeley, the plaintiff, appealed the directed verdict to the Supreme Court of Rhode Island.
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Issue:
Does Rhode Island law require an expert witness in a medical malpractice case to practice in the same specialty and the same or a similar locality as the defendant physician to be qualified to testify on the standard of care?
Opinions:
Majority - Goldberg, Justice
No. Rhode Island law does not require an expert witness to be from the same specialty or locality as the defendant; rather, the expert must possess the requisite knowledge, skill, or experience in the field of the alleged malpractice. The court's reasoning rests on several key points. First, it cites its own precedent in Buja v. Morningstar, which held that the relevant statute, § 9-19-41, does not mandate that an expert practice in the same specialty, only that they be an expert 'in the field of the alleged malpractice.' In this case, the alleged malpractice was an obstetric procedure (an episiotomy), and the proposed expert, Dr. Leslie, was a board-certified obstetrician/gynecologist with extensive experience. Therefore, the trial court abused its discretion in excluding his testimony. Second, the court takes the opportunity to formally abandon the 'similar locality' rule, which it deems an anachronism in an age of modern transportation, communication, and standardized medical education. The court joins a growing number of jurisdictions in adopting a national standard of care, holding that a physician must exercise the skill of a reasonably competent practitioner in their class under similar circumstances. The court concludes that the legislature's omission of the locality rule from § 9-19-41 was a deliberate recognition of this national approach to medical standards.
Analysis:
This decision significantly modernizes medical malpractice law in Rhode Island by formally abandoning the 'similar locality' rule in favor of a national standard of care. This change broadens the pool of available expert witnesses for plaintiffs, making it easier to establish the standard of care and prove a breach without being constrained by a potentially limited or unwilling local medical community. By focusing on the expert's knowledge of the specific procedure rather than their specialty, the ruling makes it more difficult for defendants to disqualify highly qualified experts on technical grounds. The case sets a new, clearer precedent that aligns Rhode Island with the majority of states and reflects the modern realities of a nationalized medical profession.
