Michelle Sampson v. Surgery Center

Summary

The Arizona Supreme Court held that a medical-malpractice plaintiff may not rely on a jury's unsupported inference of causation when the cause of death is disputed and requires medical knowledge. The plaintiff's expert established a possible standard-of-care violation but did not testify that the premature discharge probably caused the child's death, making the evidence legally insufficient. The court affirmed partial summary judgment for the defendants and vacated the contrary court-of-appeals decision.