Hannah v. Naughton

Supreme Court of Alabama

Etowah County | 328 So. 3d 777 | Sept. 25, 2020


A Prospective Expert Should Be Board-Certified at the Time of Testimony

The case revolves around Regina D. Hannah's appeal from a summary judgment entered by the Etowah Circuit Court in favor of Michael J. Naughton, M.D., and others. Hannah's claims of medical malpractice were based on the argument that Dr. Brickman, her chosen expert, did not need to be board-certified in general surgery at the time of his testimony.

Hannah's misrepresentation claim was founded on the alleged lie that she had cervical cancer and the only treatment option was a full hysterectomy. After analyzing the circumstance and Hannah's claim, the court affirmed that a proposed expert should be board-certified at the time of testimony and that Hannah’s claims require beyond layperson's common knowledge, which necessitates expert testimony. Her request for more time to find a new expert was also turned down, which lead to the affirmance of the summary judgment in favor of the defendants.

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