Marquardt v. SchaffhausenAnnotate this Case
In this medical malpractice case, the Supreme Court reversed the decision of the court of appeals concluding that the district court abused its discretion by admitting testimony about causation from Dr. John Stark, an orthopedic surgeon, and Dr. Kevin Stephan, an infection-disease specialist, holding that the district court did not abuse its discretion in admitting the doctors' causation testimony.
This action arose from right-knee arthroplasty Dr. James Schaffhausen performed on Plaintiff. In her complaint, Plaintiff argued that, as a result of the surgery, she suffered permanent neurologic damage. The jury found for Plaintiff. Dr. Schaffhausen moved for judgment as a matter of law or a new trial, arguing that it was error for Dr. Stark and Dr. Stephan to testify as to causation because they were not neurologists. The district court denied the motions. The court of appeals reversed, concluding that the experts were not qualified to testify as to causation because they lacked the requisite occupational experience in neurology. The Supreme Court reversed, holding that where the district court carefully weighed the qualifications of Dr. Stark and Dr. Stephan before deciding to admit their testimony, the court did not abuse its discretion in admitting their testimony on the issue of causation.