Christine Culliton, as Personal Representative of the Estate of Courtney Culliton v. Hope Community Resources, Inc.

Summary

The court held that the estate did not need expert testimony to establish breach because its claim was based on ordinary negligence—failure to follow an aspiration-notification protocol—rather than professional judgment. Expert medical testimony was required to establish the complex causal links between the aspiration, pneumonia, delayed treatment, and death, but the treating physician’s deposition supplied sufficient evidence to create a genuine dispute of material fact. The court therefore reversed summary judgment and remanded for further proceedings.