Estate of Linda Horn v. Michael J Swofford Do

Summary

The Michigan Supreme Court partially overruled its prior interpretation of the medical-malpractice expert-qualification statute, holding that the statutory matching requirement applies to general board-certification specialties and does not require matching subspecialties. It held that trial courts must still independently evaluate an expert’s training, specialization, experience, relevance, and other grounds for exclusion. Applying that rule, the Court upheld the result allowing the neuroradiology expert to testify in Stokes but remanded for reconsideration under the correct reasoning, and remanded Selliman for a fact-intensive determination whether facial plastic and reconstructive surgery is a specialty or subspecialty.