Court Discusses Expert Qualifications in Maryland Medical Malpractice Cases

Medical malpractice litigation often turns not only on clinical facts but also on procedural and evidentiary rules that determine whether a claim can proceed to trial. A recent Maryland decision highlights how expert witness qualifications and trial rulings can shape the outcome of complex negligence claims involving multiple healthcare providers. If you were harmed by negligent medical care, it is smart to speak to a Baltimore medical malpractice attorney to protect your rights.

Case Setting

Allegedly, the decedent underwent an upper endoscopy at an outpatient surgical facility and was discharged shortly after the procedure, despite multiple health conditions that could increase fall risk. After leaving the facility, the decedent fell outside while walking to a vehicle and later suffered complications that led to death.

It is alleged that the plaintiffs filed a medical negligence and wrongful death action against several healthcare providers and the facility, asserting that the defendants failed to properly assess fall risk, failed to monitor the patient adequately, and discharged the patient without appropriate assistance, such as a wheelchair. The plaintiffs supported their claims with expert certifications from physicians who opined that the defendants deviated from the applicable standards of care and that those deviations caused the decedent’s injuries and death.

Reportedly, one defendant physician moved for summary judgment, arguing that the plaintiffs lacked a qualified expert under the Maryland Health Care Malpractice Claims Act because their experts were not board-certified in the same specialty. The trial court agreed and granted summary judgment in favor of that physician.

It is reported that the case proceeded to trial against the remaining defendants, where a jury returned verdicts finding no breach of the standard of care. The plaintiffs appealed, challenging both the summary judgment ruling and several trial court decisions.

Expert Qualifications in Maryland Medical Malpractice Cases

On appeal, the court conducted a de novo review of the summary judgment ruling, applying the same legal standard as the trial court. It emphasized that, in medical malpractice cases, plaintiffs must present qualified expert testimony to establish the applicable standard of care, breach, causation, and damages. The court focused on the statutory requirement that, when a defendant is board-certified, an expert must be board-certified in the same or a related specialty.

The court analyzed whether anesthesiology and gastroenterology constituted “related specialties” under the statute. It explained that specialties are considered related when there is a meaningful overlap in treatment or procedures relevant to the issues in dispute. Here, the expert’s opinions addressed post-procedure care and discharge decisions rather than the endoscopy itself. The court found that both specialists share responsibilities in post-anesthesia recovery and discharge assessments, creating sufficient overlap in this context.

Based on this reasoning, the court held that the trial court erred in excluding the expert and granting summary judgment. As such, the court reversed that ruling and remanded the claims against the physician and related entities for further proceedings.

The court then addressed whether the erroneous summary judgment affected the jury’s verdict in favor of the remaining defendants. Applying a prejudice standard, the court determined that the plaintiffs failed to show that the error likely influenced the jury’s findings. The claims against the other defendants involved distinct duties and evidence, and the jury’s determinations rested on separate factual considerations.

The court also reviewed additional trial rulings, including evidentiary exclusions and jury instructions, and concluded that none created reversible error. Accordingly, the court affirmed the verdicts in favor of the remaining defendants while reversing in part and remanding the case for further litigation against the previously dismissed parties.

Speak to an Experienced Baltimore Medical Malpractice Attorney at Arfaa Law Group

Medical malpractice claims demand careful attention to expert qualifications, evidentiary standards, and procedural strategy. If you or a loved one has suffered harm due to negligent medical care, it is critical to speak to an attorney promptly. The experienced Baltimore medical malpractice attorneys at Arfaa Law Group possess the knowledge and experience necessary to handle complex litigation and we can aid you in seeking any damages you may be owed. Call (410) 889-1850 or use the firm’s online form to schedule a consultation and discuss your potential claim.

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