AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

• The Plaintiff, Sherry Chavarria, filed a medical negligence claim against her chiropractor, Dr. Sheila Williams, alleging that the chiropractic treatment she received caused her back pain. The treatment in question occurred on April 14, 2008, after Chavarria had been experiencing pain over the previous weekend. She returned for additional treatment the next day, during which she felt a "sharp pain" when twisting her body. Chavarria had been seeing Dr. Williams for several years for back pain treatment prior to this incident (para 3).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Plaintiff-Appellant: Argued that the chiropractic treatment received from Dr. Williams caused her injuries and that this issue could be determined without expert medical evidence, relying on common knowledge (para 4).
• Defendant-Appellee: Submitted an affidavit with expert opinion stating that the Plaintiff's back pain was caused by a preexisting disc bulge and not by the treatment provided. Also argued that there was no breach of the standard of care in the treatment of the Plaintiff (para 2).

Legal Issues

• Whether expert medical evidence is required to establish the elements of departure from the proper standard of care and causation in medical malpractice actions involving chiropractic treatment (para 2).
• Whether the Plaintiff's injuries could be determined without expert medical evidence by resorting to common knowledge (para 3).

Disposition

• The Court of Appeals affirmed the order granting summary judgment in favor of Dr. Sheila Williams, the Defendant-Appellee (para 5).

Reasons

• Per JAMES J. WECHSLER, Judge (MICHAEL D. BUSTAMANTE, Judge, MICHAEL E. VIGIL, Judge concurring):
  The Court held that expert medical evidence is generally essential to establish the elements of both departure from the proper standard of care and causation in medical malpractice actions. The Court found that the Plaintiff failed to counter the Defendant's expert evidence with any expert testimony of her own, relying instead on her lay opinion about causation, which was insufficient (para 2). The Court also considered and rejected the Plaintiff's reliance on Mascarenas v. Gonzales to argue that a jury could determine the cause of her injuries using common knowledge. The Court distinguished the present case from Mascarenas, noting that in this case, there was evidence that the Plaintiff's pain and disc bulge predated the treatment alleged to have caused harm, making it impossible for a jury to resolve the questions of causation and breach of standard of care without expert testimony (para 4).