## Facts

- Joanne Sheeley delivered a healthy child at Memorial Hospital in Pawtucket, Rhode Island on May 19, 1987.
- Dr. Mary Ryder, a second-year family-practice resident, provided obstetrical care under the supervision of Dr. Brian Jack.
- During delivery, Dr. Ryder performed and repaired an episiotomy.
- After discharge, Sheeley developed complications at the episiotomy site, including a rectovaginal fistula requiring corrective surgery, and continued pain and discomfort.
- Joanne Sheeley and her husband, Mark Sheeley, sued Memorial Hospital, Dr. Ryder, and Dr. Jack, alleging negligent performance and repair of the episiotomy.
- Plaintiffs sought to present Dr. Stanley D. Leslie, a board-certified OB/GYN, to testify on the applicable standard of care and breach.
- Defendants moved to exclude Dr. Leslie, arguing state law required a same-specialty expert and that the similar-locality rule barred his testimony.
- The trial court excluded Dr. Leslie and, with no other expert evidence for plaintiffs, directed a verdict for defendants.

## Issues

1. Whether the trial court erred in excluding the plaintiffs’ expert under R.I. Gen. Laws § 9-19-41 on the theory that an OB/GYN could not testify about the standard of care for a family-practice resident providing obstetrical care.
2. Whether Rhode Island should retain the similar-locality rule for medical malpractice standard-of-care proof and expert admissibility.
3. Whether the directed verdict for defendants was proper when it followed the exclusion of plaintiffs’ only expert.

## Decision

- The Rhode Island Supreme Court reversed the directed verdict and remanded for a new trial.
- The court held the trial court erred, and abused its discretion, by excluding Dr. Leslie’s testimony.
- The court abandoned the similar-locality rule for Rhode Island medical malpractice actions.
- The court adopted a broader standard focusing on reasonable care under the same or similar circumstances, and expert qualification based on relevant knowledge and experience with the procedure at issue rather than geography or rigid specialty matching.

## Legal Principles

- In medical malpractice actions, expert admissibility and standard-of-care proof are not limited by a similar-locality requirement; geographic similarity is not a controlling screen for expert testimony.
- R.I. Gen. Laws § 9-19-41 does not impose a strict same-specialty requirement; it sets minimum expert qualifications and permits testimony when the witness has sufficient training, knowledge, and experience relevant to the disputed care.
- Expert qualification may be procedure-based: an expert from a different specialty may testify if competent regarding the specific treatment, technique, and standards involved.
- When the exclusion of necessary expert testimony rests on an incorrect legal standard, a directed verdict entered because the plaintiff lacks expert proof cannot stand.

## Conclusion

The court ordered a new trial, holding that expert qualification in Rhode Island medical malpractice cases turns on relevant competence regarding the procedure and circumstances, not a similar-locality limitation or rigid specialty identity, and that the plaintiffs’ OB/GYN expert should have been permitted to testify.


Sheeley v. Mem'l Hosp., 710 A.2d 161 (R.I. 1998)