Medical Expert Opinion

Standard of Care
Model Instructions for Potential Medical Expert Witnesses

The following wording of instructions is offered as a template, to be modified for the particular circumstances. We recommend that the instructions be combined with carefully-crafted, forced-choice questions that the medical expert witness should address in preparing draft written expert opinion.

Please restrict your opinions to standard of care of the defendant (type of specialist[s]) and avoid commenting on whether standard care would have resulted in a materially different outcome.

Such causation issues will be addressed by (specialty) expert opinion.

As far as possible, express yourself in layman’s language and explain any necessary medical terminology.

Please supplement opinions that arise from your personal professional experience with contemporaneous Clinical Practice Guidelines and quality, referenced medical research papers (Evidence Based Medicine).

The standard of care against which the care of the each defendant physician must be judged is that of a reasonably conscientious peer in his situation.

The court is interested only in identifying elements of the care that is, in your considered opinion, substandard: an aspect of care that is merely suboptimal can be considered only if it is a component of substandard care.

If you find yourself unsupportive of our client’s position, we ask that you restrict yourself to a verbal opinion, to conserve resources.

While not wishing to impose an unfamiliar style of expert opinion, we ask that you include the following sections in any written report:

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