Michelle D. Morgan v. Publix Super Markets, Inc.

Supreme Court of Alabama

Jefferson County | 138 So. 3d 982 | Aug. 16, 2013


Expert Not Required where a Pharmacy Dispenses Incorrect Medication

Michelle D. Morgan, sued Publix Super Markets, Inc., alleging she was dispensed the wrong medication from their pharmacy, causing her to experience a series of health issues. The Jefferson Circuit Court initially ruled in favor of Publix, maintaining that under the Alabama Medical Liability Act (AMLA), Morgan was required to prove breach of care through expert testimony, which she had failed to present.

The Supreme Court of Alabama reversed and remanded, stating that where a pharmacy dispenses incorrect medication, negligence is so apparent that it can be understood by a layperson without the requirement of expert testimony. The Court relied on previous cases which upheld that negligence in such scenarios was clearly discernible by common knowledge. The case was remanded for further consistent proceedings. 

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