medical standard in Georgia

2025As a general rule, when facts alleged as constituting gross negligence are such that there is room for difference of opinion between reasonable people as to whether or not negligence can be inferred, and if so whether in degree the negligence amounts to gross negligence, the right to draw the inference is within the exclusive province of the jury.25 24 OCGA § 51-1-4. 25 (Citations and punctuation omitted.) Abdel-Samed, 294 Ga. at 765 (3) (where plaintiffs submitted expert testimony that emergency room doctor and physician assistant did not meet the medical standard of care under like circumsta

2019See Bonds v. Nesbitt, 322 Ga. App. 852, 855-856 (1) ( 747 SE2d 40 ) (2013) (doctor’s determination that patient was stable raised a jury question as to whether the patient “at some point had stabilized and was capable of receiving medical treatment as a nonemergency patient within the meaning of OCGA § 51-1-29.5 (a) (5)”) (punctuation omitted). 16 Moreover, assuming OCGA § 51-1-29.5 (c) applied, “liability [is] authorized where the evidence, including admissible expert testimony, would permit a jury to find by clear and convincing evidence that the [medical providers] caused harm by grossly de

2024Stevedore Co. v. Rambo, 521 U.S. 121, 137 (II) n.9 ( 117 SCt 1953 , 138 LEd2d 327 ) (1997); United States v. Almedina, 686 F3d 1312, 1315 (III) (11th Cir. 2012); United States v. Trainor, 376 F3d 1325, 1331 (III) (A) (11th Cir. 2004). 9 Additionally, we have held that to recover in a medical-malpractice case based on wrongful death, a plaintiff “must show not only a violation of the applicable medical standard of care but also that the purported violation or deviation from the proper standard of care is the proximate cause of the injury sustained.”17 And significantly, to satisfy this burden,

2024Stevedore Co. v. Rambo, 521 U.S. 121, 137 (II) n.9 ( 117 SCt 1953 , 138 LEd2d 327 ) (1997); United States v. Almedina, 686 F3d 1312, 1315 (III) (11th Cir. 2012); United States v. Trainor, 376 F3d 1325, 1331 (III) (A) (11th Cir. 2004). 9 Additionally, we have held that to recover in a medical-malpractice case based on wrongful death, a plaintiff “must show not only a violation of the applicable medical standard of care but also that the purported violation or deviation from the proper standard of care is the proximate cause of the injury sustained.”17 And significantly, to satisfy this burden,

2024Stevedore Co. v. Rambo, 521 U.S. 121, 137 (II) n.9 ( 117 SCt 1953 , 138 LEd2d 327 ) (1997); United States v. Almedina, 686 F3d 1312, 1315 (III) (11th Cir. 2012); United States v. Trainor, 376 F3d 1325, 1331 (III) (A) (11th Cir. 2004). 9 Additionally, we have held that to recover in a medical-malpractice case based on wrongful death, a plaintiff “must show not only a violation of the applicable medical standard of care but also that the purported violation or deviation from the proper standard of care is the proximate cause of the injury sustained.”17 And significantly, to satisfy this burden,

2021“To recover in a medical malpractice case, a plaintiff must show not only a violation of the applicable medical standard of care but also that the purported violation or deviation from the proper standard of care is the proximate cause of the injury sustained.” (Citation and punctuation omitted.) Knight v. Roberts, 316 Ga. App. 599, 603 (1) ( 730 SE2d 78 ) (2012).

2013See Bass, supra, 309 Ga. App. at 607 (3) (c) (appellant failed to establish that his counsel was deficient in failing to employ expert when he did not call trial counsel to testify at motion for new trial hearing); Nichols v. State, 253 Ga. App. 512, 515-516 (2) ( 559 SE2d 538 ) (2002) (without trial counsel’s testimony at hearing on motion to withdraw guilty plea, this Court must presume that trial counsel’s decisions concerning psychological testing of appellant and pursuit of a medical defense were strategic and not deficient).

2013See Bass, supra, 309 Ga. App. at 607 (3) (c) (appellant failed to establish that his counsel was deficient in failing to employ expert when he did not call trial counsel to testify at motion for new trial hearing); Nichols v. State, 253 Ga. App. 512, 515-516 (2) ( 559 SE2d 538 ) (2002) (without trial counsel’s testimony at hearing on motion to withdraw guilty plea, this Court must presume that trial counsel’s decisions concerning psychological testing of appellant and pursuit of a medical defense were strategic and not deficient).

2013See Bass, supra, 309 Ga. App. at 607 (3) (c) (appellant failed to establish that his counsel was deficient in failing to employ expert when he did not call trial counsel to testify at motion for new trial hearing); Nichols v. State, 253 Ga. App. 512, 515-516 (2) ( 559 SE2d 538 ) (2002) (without trial counsel’s testimony at hearing on motion to withdraw guilty plea, this Court must presume that trial counsel’s decisions concerning psychological testing of appellant and pursuit of a medical defense were strategic and not deficient).

2013See Bass, supra, 309 Ga. App. at 607 (3) (c) (appellant failed to establish that his counsel was deficient in failing to employ expert when he did not call trial counsel to testify at motion for new trial hearing); Nichols v. State, 253 Ga. App. 512, 515-516 (2) ( 559 SE2d 538 ) (2002) (without trial counsel’s testimony at hearing on motion to withdraw guilty plea, this Court must presume that trial counsel’s decisions concerning psychological testing of appellant and pursuit of a medical defense were strategic and not deficient).

2006However, the law is clear "that medical treatment of a compensable injury in a medical only claim is not subject to [OCGA § 34-9-104,] the change of condition statute. . . ." Wier v. Skyline Messenger Service, 203 Ga.App. 673, 675 (2), 417 S.E.2d 693 (1992).

2006However, the law is clear "that medical treatment of a compensable injury in a medical only claim is not subject to [OCGA § 34-9-104,] the change of condition statute. . . ." Wier v. Skyline Messenger Service, 203 Ga.App. 673, 675 (2), 417 S.E.2d 693 (1992).

2024See also Pneumo Abex, LLC v. Long, 357 Ga. App. 17 , 21 (1) (a) ( 849 SE2d 746 ) (2020) (in order to recover in a medical-malpractice case, a plaintiff is required to show a violation of the applicable medical standard of care and “that the purported violation or deviation from the proper standard of care is the proximate cause of the injury sustained”) (citation and punctuation omitted).

2024See also Pneumo Abex, LLC v. Long, 357 Ga. App. 17 , 21 (1) (a) ( 849 SE2d 746 ) (2020) (in order to recover in a medical-malpractice case, a plaintiff is required to show a violation of the applicable medical standard of care and “that the purported violation or deviation from the proper standard of care is the proximate cause of the injury sustained”) (citation and punctuation omitted).

2017To be grossly negligent, the defendant must breach the ordinary standard of care to a greater degree." (Citations and punctuation omitted.) Id. at 83 (1), 751 S.E.2d 288 (Blackwell, Justice, concurring specially, joined by Justice Nahmias). 16 "[T]he heightened evidentiary burden imposed in cases falling under OCGA § 51-1-29.5 (c) must necessarily be considered [if raised, for instance] on a motion for summary judgment. [And when] faced with such a heightened burden, a trial judge must bear in mind the actual quantum and quality of proof necessary to support liability." Johnson , 294 Ga. at 77

2017To be grossly negligent, the defendant must breach the ordinary standard of care to a greater degree." (Citations and punctuation omitted.) Id. at 83 (1), 751 S.E.2d 288 (Blackwell, Justice, concurring specially, joined by Justice Nahmias). 16 "[T]he heightened evidentiary burden imposed in cases falling under OCGA § 51-1-29.5 (c) must necessarily be considered [if raised, for instance] on a motion for summary judgment. [And when] faced with such a heightened burden, a trial judge must bear in mind the actual quantum and quality of proof necessary to support liability." Johnson , 294 Ga. at 77

2025If a healthcare provider in the treatment and care of a patient exercised that degree of care and skill ordinarily employed by the profession generally under similar conditions and like surrounding circumstances, then the healthcare provider would not be negligent or grossly negligent; therefore, there could be no finding of malpractice.[35] If, on the other hand, the healthcare provider should be substantially and grossly deviate from the requisite degree of care and skill, the healthcare provider would be grossly negligent. ... 34 See Suggested Pattern Jury Instructions, Vol. I: Civil Cases

2025If a healthcare provider in the treatment and care of a patient exercised that degree of care and skill ordinarily employed by the profession generally under similar conditions and like surrounding circumstances, then the healthcare provider would not be negligent or grossly negligent; therefore, there could be no finding of malpractice.[35] If, on the other hand, the healthcare provider should be substantially and grossly deviate from the requisite degree of care and skill, the healthcare provider would be grossly negligent. ... 34 See Suggested Pattern Jury Instructions, Vol. I: Civil Cases

2025Nonetheless, as discussed in Division 4 (a), the evidence permitted a jury to find by clear and convincing evidence that Womack caused harm by grossly deviating from the applicable medical standard of care.28 Based on the evidence, including the expert testimony, the jury could find the absence of even “slight diligence.” (c) Dr. Womack also contends that Buckelew failed to show causation because Buckelew’s expert witness, Dr. Raul Nogueira, opined only that Buckelew’s injuries would have been less severe if he had received the “best care.” Dr. Nogueira, an expert in interventional neurology,

2025Nonetheless, as discussed in Division 4 (a), the evidence permitted a jury to find by clear and convincing evidence that Womack caused harm by grossly deviating from the applicable medical standard of care.28 Based on the evidence, including the expert testimony, the jury could find the absence of even “slight diligence.” (c) Dr. Womack also contends that Buckelew failed to show causation because Buckelew’s expert witness, Dr. Raul Nogueira, opined only that Buckelew’s injuries would have been less severe if he had received the “best care.” Dr. Nogueira, an expert in interventional neurology,

2025If a healthcare provider in the treatment and care of a patient exercised that degree of care and skill ordinarily employed by the profession generally under similar conditions and like surrounding circumstances, then the healthcare provider would not be negligent or grossly negligent; therefore, there could be no finding of malpractice.[35] If, on the other hand, the healthcare provider should be substantially and grossly deviate from the requisite degree of care and skill, the healthcare provider would be grossly negligent. ... 34 See Suggested Pattern Jury Instructions, Vol. I: Civil Cases

2025If a healthcare provider in the treatment and care of a patient exercised that degree of care and skill ordinarily employed by the profession generally under similar conditions and like surrounding circumstances, then the healthcare provider would not be negligent or grossly negligent; therefore, there could be no finding of malpractice.[35] If, on the other hand, the healthcare provider should be substantially and grossly deviate from the requisite degree of care and skill, the healthcare provider would be grossly negligent. ... 34 See Suggested Pattern Jury Instructions, Vol. I: Civil Cases

2025If a healthcare provider in the treatment and care of a patient exercised that degree of care and skill ordinarily employed by the profession generally under similar conditions and like surrounding circumstances, then the healthcare provider would not be negligent or grossly negligent; therefore, there could be no finding of malpractice.[35] If, on the other hand, the healthcare provider should be substantially and grossly deviate from the requisite degree of care and skill, the healthcare provider would be grossly negligent. ... 34 See Suggested Pattern Jury Instructions, Vol. I: Civil Cases

2025If a healthcare provider in the treatment and care of a patient exercised that degree of care and skill ordinarily employed by the profession generally under similar conditions and like surrounding circumstances, then the healthcare provider would not be negligent or grossly negligent; therefore, there could be no finding of malpractice.[35] If, on the other hand, the healthcare provider should be substantially and grossly deviate from the requisite degree of care and skill, the healthcare provider would be grossly negligent. ... 34 See Suggested Pattern Jury Instructions, Vol. I: Civil Cases

2025Nonetheless, as discussed in Division 4 (a), the evidence permitted a jury to find by clear and convincing evidence that Womack caused harm by grossly deviating from the applicable medical standard of care.28 Based on the evidence, including the expert testimony, the jury could find the absence of even “slight diligence.” (c) Dr. Womack also contends that Buckelew failed to show causation because Buckelew’s expert witness, Dr. Raul Nogueira, opined only that Buckelew’s injuries would have been less severe if he had received the “best care.” Dr. Nogueira, an expert in interventional neurology,

2025Nonetheless, as discussed in Division 4 (a), the evidence permitted a jury to find by clear and convincing evidence that Womack caused harm by grossly deviating from the applicable medical standard of care.28 Based on the evidence, including the expert testimony, the jury could find the absence of even “slight diligence.” (c) Dr. Womack also contends that Buckelew failed to show causation because Buckelew’s expert witness, Dr. Raul Nogueira, opined only that Buckelew’s injuries would have been less severe if he had received the “best care.” Dr. Nogueira, an expert in interventional neurology,

2025If a healthcare provider in the treatment and care of a patient exercised that degree of care and skill ordinarily employed by the profession generally under similar conditions and like surrounding circumstances, then the healthcare provider would not be negligent or grossly negligent; therefore, there could be no finding of malpractice.[35] If, on the other hand, the healthcare provider should be substantially and grossly deviate from the requisite degree of care and skill, the healthcare provider would be grossly negligent. ... 34 See Suggested Pattern Jury Instructions, Vol. I: Civil Cases

2025If a healthcare provider in the treatment and care of a patient exercised that degree of care and skill ordinarily employed by the profession generally under similar conditions and like surrounding circumstances, then the healthcare provider would not be negligent or grossly negligent; therefore, there could be no finding of malpractice.[35] If, on the other hand, the healthcare provider should be substantially and grossly deviate from the requisite degree of care and skill, the healthcare provider would be grossly negligent. ... 34 See Suggested Pattern Jury Instructions, Vol. I: Civil Cases

2024Stevedore Co. v. Rambo, 521 U.S. 121, 137 (II) n.9 ( 117 SCt 1953 , 138 LEd2d 327 ) (1997); United States v. Almedina, 686 F3d 1312, 1315 (III) (11th Cir. 2012); United States v. Trainor, 376 F3d 1325, 1331 (III) (A) (11th Cir. 2004). 9 Additionally, we have held that to recover in a medical-malpractice case based on wrongful death, a plaintiff “must show not only a violation of the applicable medical standard of care but also that the purported violation or deviation from the proper standard of care is the proximate cause of the injury sustained.”17 And significantly, to satisfy this burden,

2024Stevedore Co. v. Rambo, 521 U.S. 121, 137 (II) n.9 ( 117 SCt 1953 , 138 LEd2d 327 ) (1997); United States v. Almedina, 686 F3d 1312, 1315 (III) (11th Cir. 2012); United States v. Trainor, 376 F3d 1325, 1331 (III) (A) (11th Cir. 2004). 9 Additionally, we have held that to recover in a medical-malpractice case based on wrongful death, a plaintiff “must show not only a violation of the applicable medical standard of care but also that the purported violation or deviation from the proper standard of care is the proximate cause of the injury sustained.”17 And significantly, to satisfy this burden,

2024Stevedore Co. v. Rambo, 521 U.S. 121, 137 (II) n.9 ( 117 SCt 1953 , 138 LEd2d 327 ) (1997); United States v. Almedina, 686 F3d 1312, 1315 (III) (11th Cir. 2012); United States v. Trainor, 376 F3d 1325, 1331 (III) (A) (11th Cir. 2004). 9 Additionally, we have held that to recover in a medical-malpractice case based on wrongful death, a plaintiff “must show not only a violation of the applicable medical standard of care but also that the purported violation or deviation from the proper standard of care is the proximate cause of the injury sustained.”17 And significantly, to satisfy this burden,

2024Stevedore Co. v. Rambo, 521 U.S. 121, 137 (II) n.9 ( 117 SCt 1953 , 138 LEd2d 327 ) (1997); United States v. Almedina, 686 F3d 1312, 1315 (III) (11th Cir. 2012); United States v. Trainor, 376 F3d 1325, 1331 (III) (A) (11th Cir. 2004). 9 Additionally, we have held that to recover in a medical-malpractice case based on wrongful death, a plaintiff “must show not only a violation of the applicable medical standard of care but also that the purported violation or deviation from the proper standard of care is the proximate cause of the injury sustained.”17 And significantly, to satisfy this burden,

2024Stevedore Co. v. Rambo, 521 U.S. 121, 137 (II) n.9 ( 117 SCt 1953 , 138 LEd2d 327 ) (1997); United States v. Almedina, 686 F3d 1312, 1315 (III) (11th Cir. 2012); United States v. Trainor, 376 F3d 1325, 1331 (III) (A) (11th Cir. 2004). 9 Additionally, we have held that to recover in a medical-malpractice case based on wrongful death, a plaintiff “must show not only a violation of the applicable medical standard of care but also that the purported violation or deviation from the proper standard of care is the proximate cause of the injury sustained.”17 And significantly, to satisfy this burden,

2024Stevedore Co. v. Rambo, 521 U.S. 121, 137 (II) n.9 ( 117 SCt 1953 , 138 LEd2d 327 ) (1997); United States v. Almedina, 686 F3d 1312, 1315 (III) (11th Cir. 2012); United States v. Trainor, 376 F3d 1325, 1331 (III) (A) (11th Cir. 2004). 9 Additionally, we have held that to recover in a medical-malpractice case based on wrongful death, a plaintiff “must show not only a violation of the applicable medical standard of care but also that the purported violation or deviation from the proper standard of care is the proximate cause of the injury sustained.”17 And significantly, to satisfy this burden,

2024Stevedore Co. v. Rambo, 521 U.S. 121, 137 (II) n.9 ( 117 SCt 1953 , 138 LEd2d 327 ) (1997); United States v. Almedina, 686 F3d 1312, 1315 (III) (11th Cir. 2012); United States v. Trainor, 376 F3d 1325, 1331 (III) (A) (11th Cir. 2004). 9 Additionally, we have held that to recover in a medical-malpractice case based on wrongful death, a plaintiff “must show not only a violation of the applicable medical standard of care but also that the purported violation or deviation from the proper standard of care is the proximate cause of the injury sustained.”17 And significantly, to satisfy this burden,

2024Stevedore Co. v. Rambo, 521 U.S. 121, 137 (II) n.9 ( 117 SCt 1953 , 138 LEd2d 327 ) (1997); United States v. Almedina, 686 F3d 1312, 1315 (III) (11th Cir. 2012); United States v. Trainor, 376 F3d 1325, 1331 (III) (A) (11th Cir. 2004). 9 Additionally, we have held that to recover in a medical-malpractice case based on wrongful death, a plaintiff “must show not only a violation of the applicable medical standard of care but also that the purported violation or deviation from the proper standard of care is the proximate cause of the injury sustained.”17 And significantly, to satisfy this burden,

2024Stevedore Co. v. Rambo, 521 U.S. 121, 137 (II) n.9 ( 117 SCt 1953 , 138 LEd2d 327 ) (1997); United States v. Almedina, 686 F3d 1312, 1315 (III) (11th Cir. 2012); United States v. Trainor, 376 F3d 1325, 1331 (III) (A) (11th Cir. 2004). 9 Additionally, we have held that to recover in a medical-malpractice case based on wrongful death, a plaintiff “must show not only a violation of the applicable medical standard of care but also that the purported violation or deviation from the proper standard of care is the proximate cause of the injury sustained.”17 And significantly, to satisfy this burden,

2024Stevedore Co. v. Rambo, 521 U.S. 121, 137 (II) n.9 ( 117 SCt 1953 , 138 LEd2d 327 ) (1997); United States v. Almedina, 686 F3d 1312, 1315 (III) (11th Cir. 2012); United States v. Trainor, 376 F3d 1325, 1331 (III) (A) (11th Cir. 2004). 9 Additionally, we have held that to recover in a medical-malpractice case based on wrongful death, a plaintiff “must show not only a violation of the applicable medical standard of care but also that the purported violation or deviation from the proper standard of care is the proximate cause of the injury sustained.”17 And significantly, to satisfy this burden,

2024Stevedore Co. v. Rambo, 521 U.S. 121, 137 (II) n.9 ( 117 SCt 1953 , 138 LEd2d 327 ) (1997); United States v. Almedina, 686 F3d 1312, 1315 (III) (11th Cir. 2012); United States v. Trainor, 376 F3d 1325, 1331 (III) (A) (11th Cir. 2004). 9 Additionally, we have held that to recover in a medical-malpractice case based on wrongful death, a plaintiff “must show not only a violation of the applicable medical standard of care but also that the purported violation or deviation from the proper standard of care is the proximate cause of the injury sustained.”17 And significantly, to satisfy this burden,

2024Stevedore Co. v. Rambo, 521 U.S. 121, 137 (II) n.9 ( 117 SCt 1953 , 138 LEd2d 327 ) (1997); United States v. Almedina, 686 F3d 1312, 1315 (III) (11th Cir. 2012); United States v. Trainor, 376 F3d 1325, 1331 (III) (A) (11th Cir. 2004). 9 Additionally, we have held that to recover in a medical-malpractice case based on wrongful death, a plaintiff “must show not only a violation of the applicable medical standard of care but also that the purported violation or deviation from the proper standard of care is the proximate cause of the injury sustained.”17 And significantly, to satisfy this burden,

2020That includes not only the plaintiff himself and defendants with liability to the plaintiff, but also every other tortfeasor whose commission of a tort as against the plaintiff was a proximate cause of his injury, regardless of whether such tortfeasor would have actual liability in tort to the plaintiff.” (emphasis supplied)). 18 MCG Health, Inc. v. Barton, 285 Ga. App. 577, 582 (2) ( 647 SE2d 81 ) (2007) (punctuation omitted); accord Moore v. Singh, 326 Ga. App. 805, 808 (1) ( 755 SE2d 319 ) (2014).

2020That includes not only the plaintiff himself and defendants with liability to the plaintiff, but also every other tortfeasor whose commission of a tort as against the plaintiff was a proximate cause of his injury, regardless of whether such tortfeasor would have actual liability in tort to the plaintiff.” (emphasis supplied)). 18 MCG Health, Inc. v. Barton, 285 Ga. App. 577, 582 (2) ( 647 SE2d 81 ) (2007) (punctuation omitted); accord Moore v. Singh, 326 Ga. App. 805, 808 (1) ( 755 SE2d 319 ) (2014).

2020To recover in a medical-malpractice case, a plaintiff must “show not only a violation of the applicable medical standard of care but also that the purported violation or deviation from the proper standard of care is the proximate cause of the injury sustained.”18 Indeed, a mere showing of negligence 17 See note 12 & accompanying text; Zalvidar, 297 Ga. at 600 (1) (“[W]e hold that OCGA § 51-12-33 (c) requires the trier of fact in cases to which the statute applies to ‘consider the fault of all persons or entities who contributed to the alleged injury or damages,’ meaning all persons or entities

2020That includes not only the plaintiff himself and defendants with liability to the plaintiff, but also every other tortfeasor whose commission of a tort as against the plaintiff was a proximate cause of his injury, regardless of whether such tortfeasor would have actual liability in tort to the plaintiff.” (emphasis supplied)). 18 MCG Health, Inc. v. Barton, 285 Ga. App. 577, 582 (2) ( 647 SE2d 81 ) (2007) (punctuation omitted); accord Moore v. Singh, 326 Ga. App. 805, 808 (1) ( 755 SE2d 319 ) (2014).

2020That includes not only the plaintiff himself and defendants with liability to the plaintiff, but also every other tortfeasor whose commission of a tort as against the plaintiff was a proximate cause of his injury, regardless of whether such tortfeasor would have actual liability in tort to the plaintiff.” (emphasis supplied)). 18 MCG Health, Inc. v. Barton, 285 Ga. App. 577, 582 (2) ( 647 SE2d 81 ) (2007) (punctuation omitted); accord Moore v. Singh, 326 Ga. App. 805, 808 (1) ( 755 SE2d 319 ) (2014).

2019See Bonds v. Nesbitt, 322 Ga. App. 852, 855-856 (1) ( 747 SE2d 40 ) (2013) (doctor’s determination that patient was stable raised a jury question as to whether the patient “at some point had stabilized and was capable of receiving medical treatment as a nonemergency patient within the meaning of OCGA § 51-1-29.5 (a) (5)”) (punctuation omitted). 16 Moreover, assuming OCGA § 51-1-29.5 (c) applied, “liability [is] authorized where the evidence, including admissible expert testimony, would permit a jury to find by clear and convincing evidence that the [medical providers] caused harm by grossly de

2019See Bonds v. Nesbitt, 322 Ga. App. 852, 855-856 (1) ( 747 SE2d 40 ) (2013) (doctor’s determination that patient was stable raised a jury question as to whether the patient “at some point had stabilized and was capable of receiving medical treatment as a nonemergency patient within the meaning of OCGA § 51-1-29.5 (a) (5)”) (punctuation omitted). 16 Moreover, assuming OCGA § 51-1-29.5 (c) applied, “liability [is] authorized where the evidence, including admissible expert testimony, would permit a jury to find by clear and convincing evidence that the [medical providers] caused harm by grossly de

2017“To recover in a medical malpractice case, a plaintiff must show not only a violation of the applicable medical standard of care but also that the purported violation or deviation from the proper standard of care is the proximate cause of the injury sustained.” Berrell v. Hamilton, 260 Ga. App. 892, 896 ( 581 SE2d 398 ) (2003) (citation omitted).

2017“To recover in a medical malpractice case, a plaintiff must show not only a violation of the applicable medical standard of care but also that the purported violation or deviation from the proper standard of care is the proximate cause of the injury sustained.” Berrell v. Hamilton, 260 Ga. App. 892, 896 ( 581 SE2d 398 ) (2003) (citation omitted).