Law School Case Brief
Blatz v. Allina Health Sys. - 622 N.W.2d 376 (Minn. Ct. App. 2001)
Whether expert testimony is required depends on the nature of the question to be decided by the trier of fact and on whether technical or specialized knowledge will assist the trier of fact. When a claim is predicated on conduct subject to a professional standard of care, expert evidence is generally required to support the claim. But expert testimony is not necessary when the issues are within an area of common knowledge.
Defendant Allina Health System, doing business as HealthSpan Transportation Services ("Allina"), contracted to provide paramedic and ambulance services to Jordan, Minnesota, and surrounding communities. Plaintiff Mary Blatz filed a negligence action in Minnesota state court against Allina for injuries sustained due to a delayed emergency response by Allina's ambulance. At trial, Allina sought to admit testimony of two expert witnesses on professional standards of ambulance drivers, but the district court excluded the evidence after ruling that the allegedly negligent conduct was within the knowledge of laypersons. After trial, a jury found Allina negligent in responding to a 911 call from Blatz's home and that Allina's negligence was a direct cause of Blatz's substantial injuries. Allina filed a motion for judgment notwithstanding the verdict or a new trial. Allina also requested a Schwartz hearing to inquire into the truthfulness of two jurors' voir dire responses. The district court denied the motions. Allina appealed, contending that the evidence did not support a finding of negligence or causation and that the district court abused its discretion in excluding expert evidence, denying a mistrial, declining to hold a Schwartz hearing and in instructing the jury.
Did the trial court abuse its discretion by excluding evidence?
The court affirmed the trial court's judgment. Th court noted that the district court concluded that whether Allina's paramedics were negligent in locating Blatz's house was a question largely within the jury's knowledge and experience. The district court thus ruled that expert testimony was not necessary. That ruling, the court held, was consistent with the appellate court's own conclusion that the district court appropriately instructed the jury on the reasonable-person standard of care. The court also ruled that the evidence was sufficient to support the jury verdict and did not require a mistrial, that the district court properly denied the request for a Schwartz hearing where there was no jury misconduct, and that the jury instructions were proper.
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