Katachia Dale, as Administratrix of the Estate of Mary Patricia Gulley v. Gary Kolb, D.o.

Summary

The Alabama Supreme Court reversed the trial court’s summary judgment in favor of Dr. Kolb and remanded for further proceedings. It held that the plaintiff’s expert was not certified by the same board as the defendant, that the trial court erred in refusing a continuance, and that the judge’s recusal issue was waived. The court distinguished the Wal‑Mart precedent and applied the statutory expert‑certification requirements.