Ronnie McDaniel v. Payson Healthcare

Summary

The court held that treating physicians do not violate Arizona’s One-Expert Rule when their testimony, including opinions about the standard of care, is based on their personal observations and participation in treating the plaintiff. It also held that a physician dismissed on summary judgment was not an indispensable party to a cross-appeal concerning designation as a nonparty at fault, but affirmed denial of that designation because there was no settlement and no evidence supporting fault. The court nevertheless remanded for a new trial because the lower appellate court had independently found prejudicial admission of undisclosed expert opinions.