Raines v. Lutz

This case presents the question whether the written opinion of a medical malpractice review panel, when admitted into evidence at trial pursuant to Code § 8.01-581.8, is in itself sufficient to establish a prima facie case of negligence and proximate cause for the plaintiff. The question, more specifically, is whether such a written opinion satisfies the requirements, governing professional malpractice cases generally, that the appropriate standard of care, as well as any departure from that standard, must be proved by expert testimony.

The plaintiffs, Karen Guess Raines and her sister,…