Patton v. Thompson

Dr. Rita W. Patton and her employer, the Frank Kay Psychiatric Clinic, the defendants below, were granted permission to appeal from the trial court's order denying Dr. Patton and the Clinic's "Rule 50(b)[, Ala. R. Civ. P.,] Renewed Motion for Judgment as a Matter of Law, or, Alternatively Styled, Motion for a Summary Judgment." See Rule 5, Ala. R.App. P. The trial court certified the following controlling question of law:

"The controlling question of law is the degree of proof necessary to establish the essential element of proximate causation in a medical malpractice/wrongful death action…