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REHABILITATIVE CARE SYS OF AMERICA v. Davis

Citations: 73 S.W.3d 233; 2002 WL 463714Docket: 01-0416

Court: Texas Supreme Court; May 30, 2002; Texas; State Supreme Court

Narrative Opinion Summary

In the case of Rehabilitative Care Systems of America v. Robert Jerry Davis and Kathy Davis, the Supreme Court of Texas addressed a malpractice claim involving a physical-therapy patient who alleged injuries due to negligent supervision during a rehabilitative exercise program. The jury found in favor of the patient, leading the trial court to rule against the rehabilitation center. The court of appeals recognized that establishing the standard of care in physical-therapist malpractice cases typically requires expert testimony. However, it controversially stated that the jury could ascertain the standard of care based on their own experience without expert input. The Supreme Court disapproved of this position, reinforcing that expert testimony is necessary to establish the appropriate standard of care in such cases, and ultimately denied the petition for review.

Legal Issues Addressed

Jury's Role in Determining Standard of Care

Application: The Supreme Court clarified that while the jury is tasked with determining facts, the ascertainment of the standard of care in malpractice cases requires specialized knowledge provided by experts.

Reasoning: The jury found in favor of the patient, leading the trial court to rule against the rehabilitation center.

Requirement of Expert Testimony in Malpractice Cases

Application: The Supreme Court of Texas emphasized that expert testimony is necessary to establish the standard of care in physical-therapist malpractice cases, countering the court of appeals' suggestion that a jury could determine this based on personal experience.

Reasoning: The Supreme Court disapproved of this position, reinforcing that expert testimony is necessary to establish the appropriate standard of care in such cases.

Standard of Care in Physical-Therapist Malpractice

Application: The court of appeals initially posited that a jury could ascertain the standard of care in physical-therapist malpractice cases based on their own experience without expert input, a stance ultimately rejected by the Supreme Court.

Reasoning: The court of appeals recognized that establishing the standard of care in physical-therapist malpractice cases typically requires expert testimony. However, it controversially stated that the jury could ascertain the standard of care based on their own experience without expert input.