Adams v. SietsemaAnnotate this Case
Contrary to the conclusion of the court of appeals in this medical malpractice action, Plaintiff’s failure to produce expert evidence was fatal to his claim and summary judgment was properly granted to Defendants.
Plaintiff brought this action alleging that Defendants were negligent in treating, or failing to treat, his illness while he was an inmate in the Hardin County Detention Center. The trial court dismissed Plaintiff’s claims against Defendants on summary judgment because Plaintiff had no expert evidence to establish the relevant standards of care or to show that Defendants’ breach of the standard of care caused Plaintiff’s damages. The court of appeals reversed, concluding that the negligent conduct asserted by Plaintiff fit within the res ipsa loquitur doctrine and thus could be supported at trial without expert opinion. The Supreme Court reversed, holding that, in the absence of expert testimony to the contrary, Plaintiff’s evidence failed to create a genuine issue of material fact as to Defendants’ breach of a standard of care, and therefore, as a matter of law, Defendants were correctly granted summary judgment.