plaintiff must establish standard (Rhode Island) · Go Syfert
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plaintiff must establish standard in Rhode Island

11 Rhode Island opinions name it 2 courts 1980–2023 2 in the last five years

The cases below were cited by Rhode Island courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (10)

CaseFollowedCited
Sousa v. Chasetgreen
ri · 1987 · cited in 5 Rhode Island opinions naming this issue, 2001–2009
2 sentences

2009Boccasile v. Cajun Music Ltd., 694 A.2d 686, 689-90 (R.I.1997); see also Riley v. Stone, 900 A.2d 1087, 1095 (R.I.2006); Sheeley, 710 A.2d at 164 . 14 “Expert *595 testimony is needed to explain * * * what proper procedures and alternatives are available to a physician * * * [and] to show why the procedures followed by the defendant physician were negligent, and not legitimate, alternatives.” Sousa v. Chaset, 519 A.2d 1132, 1135 (R.I.1987).

2003Souza v. Chaset, 519 A .2d 1132, 1135 (R.I. 1987).

25
Riley v. Stonegreen
ri · 2006 · cited in 2 Rhode Island opinions naming this issue, 2009–2023
2 sentences

2023It is well settled that “[i]n any negligence action, * * * the plaintiff must establish a standard of care and prove, by a preponderance of the evidence, that the defendant deviated from that standard of care.” Riley v. Stone, 900 A.2d 1087, 1095 (R.I. 2006); see also Mangiarelli v. Town of Johnston, 289 A.3d 560 , 568 (R.I. 2023).

2009Boccasile v. Cajun Music Ltd., 694 A.2d 686, 689-90 (R.I.1997); see also Riley v. Stone, 900 A.2d 1087, 1095 (R.I.2006); Sheeley, 710 A.2d at 164 . 14 “Expert *595 testimony is needed to explain * * * what proper procedures and alternatives are available to a physician * * * [and] to show why the procedures followed by the defendant physician were negligent, and not legitimate, alternatives.” Sousa v. Chaset, 519 A.2d 1132, 1135 (R.I.1987).

22
Malinou v. Miriam Hospitalgreen
ri · 2011 · cited in 2 Rhode Island opinions naming this issue, 2012–2021
2 sentences

2021See Almonte v. Kurl, 46 A.3d 1, 17 (R.I. 2012) (“It is a general rule that * * * ‘a plaintiff must establish a standard of care as well as a deviation from that standard.’”) (quoting Malinou v. Miriam Hospital, 24 A.3d 497, 509 (R.I. 2011)).

2012The Proximate Cause Requirement and Expert Testimony On appeal, plaintiffs contend that the trial justice erred in granting defendants’ Rule 50 motion for judgment as a matter of law; they point to the fact that Dr. Kurl had testified during her deposition (which testimony was read into the record at trial) that, if Mr. Almonte had been committed, “he would have been involuntarily committed/or 72 hours to the psychiatric facility.” (Emphasis added.) It is a general rule that, in a wrongful death action, as in any action sounding in negligence, “a plaintiff must establish a standard of care as

22
Boccasile v. Cajun Music Limitedgreen
ri · 1997 · cited in 2 Rhode Island opinions naming this issue, 2009–2012
2 sentences

2012Joseph Health Services of Rhode Island, 899 A.2d 1271, 1277 (R.I.2006); Boccasile v. Cajun Music Limited, 694 A.2d 686, 689 (R.I.1997).

2009Boccasile v. Cajun Music Ltd., 694 A.2d 686, 689-90 (R.I.1997); see also Riley v. Stone, 900 A.2d 1087, 1095 (R.I.2006); Sheeley, 710 A.2d at 164 . 14 “Expert *595 testimony is needed to explain * * * what proper procedures and alternatives are available to a physician * * * [and] to show why the procedures followed by the defendant physician were negligent, and not legitimate, alternatives.” Sousa v. Chaset, 519 A.2d 1132, 1135 (R.I.1987).

22
Mills v. State Sales, Inc.green
ri · 2003 · cited in 1 Rhode Island opinions naming this issue, 2023–2023
1 sentence

2023Furthermore, “expert testimony is required to establish any matter that is not obvious to a lay person and thus lies beyond common knowledge.” Mills v. State Sales, Inc., 824 A.2d 461, 468 (R.I. 2003); see also Mangiarelli, 289 A.3d at 568. 9 The plaintiff’s “negligent credentialing” claim is often referred to as a corporate negligence claim.

11
Almonte v. KURLgreen
ri · 2012 · cited in 1 Rhode Island opinions naming this issue, 2021–2021
1 sentence

2021See Almonte v. Kurl, 46 A.3d 1, 17 (R.I. 2012) (“It is a general rule that * * * ‘a plaintiff must establish a standard of care as well as a deviation from that standard.’”) (quoting Malinou v. Miriam Hospital, 24 A.3d 497, 509 (R.I. 2011)).

11
Foley v. ST. JOSEPH HEALTH SERVICESgreen
ri · 2006 · cited in 1 Rhode Island opinions naming this issue, 2012–2012
1 sentence

2012Joseph Health Services of Rhode Island, 899 A.2d 1271, 1277 (R.I.2006); Boccasile v. Cajun Music Limited, 694 A.2d 686, 689 (R.I.1997).

11
Morales v. Town of Johnstongreen
ri · 2006 · cited in 1 Rhode Island opinions naming this issue, 2006–2006
2 sentences

2006Morales v. Town of Johnston, 895 A.2d 721, 732 (R.I.2006).

2006Morales v. Town of Johnston, 895 A.2d 721, 782 (R.I.2006).

11
Scittarelli v. Providence Gas Co.green
ri · 1980 · cited in 1 Rhode Island opinions naming this issue, 2003–2003
1 sentence

2003“In order to prove negligent inspection and testing a plaintiff must establish a standard of care with respect to inspection and testing and the defendant’s deviation from that standard.” Scittarelli v. Providence Gas Co., 415 A.2d 1040, 1043 (R.I.1980).

11
Marshall v. Tomaselligreen
ri · 1977 · cited in 1 Rhode Island opinions naming this issue, 1980–1980
2 sentences

1980See Marshall v. Tomaselli, 118 R.I. at 196 , 372 A.2d at 1283 ; Prosser, Law of Torts § 53 (4th ed. 1971).

1980See Marshall v. Tomaselli, 118 R.I. at 196 , 372 A.2d at 1283 ; Prosser, Law of Torts § 53 (4th ed. 1971).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Rhode Island. Read the followed side critically anyway.

Also cited on this issue (2)

CaseCitedYears
Cheryl Daniels, Individually and as Mother and Next Friend of Anthony Daniels, a minor v. Zachery Fluette green
ri · 2013
1 sentence

2021In fact, in a case decided after Medeiros, we held, in the context of the school setting, that “a plaintiff seeking to hold a school liable for injuries resulting from the acts of another student must show that such acts could have been reasonably foreseen by the school.” Daniels, 64 A.3d at 307 .

12021–2021
Sheeley v. Memorial Hospital green
ri · 1998
1 sentence

2009Boccasile v. Cajun Music Ltd., 694 A.2d 686, 689-90 (R.I.1997); see also Riley v. Stone, 900 A.2d 1087, 1095 (R.I.2006); Sheeley, 710 A.2d at 164 . 14 “Expert *595 testimony is needed to explain * * * what proper procedures and alternatives are available to a physician * * * [and] to show why the procedures followed by the defendant physician were negligent, and not legitimate, alternatives.” Sousa v. Chaset, 519 A.2d 1132, 1135 (R.I.1987).

12009–2009

Where else courts name it

NY 63 (1929–2026) LA 51 (1964–2025) RI 11 (1980–2023) IL 10 (1979–2025) CA 9 (2022–2026) TX 5 (2000–2022) DE 3 (1914–2025) MT 2 (2014–2025) NJ 2 (1998–2015) WI 2 (2005–2025) WV 2 (2013–2013)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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