Supreme Court of New Jersey

The Estate of Angelina A. Chin by Robert Chin as Administrator and Administrator Ad Prosequendum, and Robert Chin…

July 28, 1999160 N.J. 454

Summary

The Supreme Court of New Jersey affirmed the Appellate Division, holding that the Anderson doctrine fully shifts the burden of proof to defendants in this unconscious‑patient malpractice case, that the common‑knowledge doctrine permits a lay jury to assess nursing negligence without expert testimony, and that the trial court erred in granting a judgment notwithstanding the verdict. The judgment was remanded for entry of the jury’s $2 million verdict.