Rivera Rodriguez v. Hospital San Cristobal, No. 22-1776 (1st Cir. 2024)
In Rivera Rodriguez v. Hospital San Cristobal, the First Circuit Court of Appeals affirmed the district court’s decision to grant summary judgment in favor of Hospital San Cristobal (HSC) and two doctors, Dr. Iris Vélez García and Dr. Zacarías A. Mateo Minaya, in a medical malpractice lawsuit. The plaintiffs, the children of Ramona Rodríguez Rivera, claimed that their mother died due to negligent care at HSC following an abdominal surgery performed by the two doctors.
The plaintiffs’ case hinged on the testimony of their expert witness, who was expected to establish the standard of care that HSC staff should have followed and demonstrate how the staff deviated from that standard, particularly in managing the patient’s diabetes. However, the district court excluded the expert’s testimony under Federal Rule of Evidence 702, which governs the admissibility of expert testimony. The court found that the expert’s report failed to clearly define the standard of care or specify how the defendants breached that standard.
Without this crucial expert testimony, the plaintiffs could not substantiate their claim that the defendants were negligent. The First Circuit agreed with the district court’s decision, concluding that the plaintiffs lacked the necessary evidence to prove a breach of duty of care. As a result, the appellate court upheld the summary judgment in favor of the defendants, effectively ending the case in their favor. This ruling underscores the importance of clear and specific expert testimony in medical malpractice cases to establish a breach of the standard of care.
