Guevara v. Ferrer

This case presents the question of whether expert medical evidence is required to support a finding that an automobile accident caused medical expenses of over $1 million. We conclude that expert medical evidence is required to prove causation unless competent evidence supports a finding that the conditions in question, the causal relationship between the conditions and the accident, and the necessity of the particular medical treatments for the conditions are within the common knowledge and experience of laypersons. Because only lay evidence was offered to prove that the accident caused all…