Frank Carbone, Plaintiff-Respondent v. Jack C. Warburton, Defendant-Appellant

Summary

The Supreme Court of New Jersey affirmed the Appellate Division's reversal of the trial court's dismissal of a medical malpractice action, holding that the trial judge improperly excluded the plaintiff's medical expert. The Court found the expert qualified despite being a retired New York general practitioner, rejected the claim that the exclusion was harmless, and upheld the trial court's refusal to allow certain bias‑related cross‑examination. The decision clarifies the standard of review for expert qualification determinations and the relevance of bias inquiries.