Expert testimony; Admissibility under MRE 702 & MCL 600.2955; Danhoff v Fahim; Qualifications; MCL 600.2169(2); Medical malpractice; Standard of care, breach, & causation; Rock v Crocker; Motion to strike expert’s testimony; Expert substitution after discovery; Abandonment of issue

The court held that the trial court properly struck plaintiff’s nursing expert and granted summary disposition because the expert could not reliably identify the specific breaches of the nursing standard of care or connect those alleged breaches to the decedent’s injuries, leaving plaintiff unable to prove a prima facie malpractice case. Plaintiff alleged that nursing staff at defendants-Boulevard Temple Care Center and Henry Ford entities allowed the decedent to develop and suffer worsening pressure ulcers from 2020 through 2022, causing pain, distress, loss of mobility, and deterioration in health. After discovery closed, defendants deposed plaintiff’s sole expert, a nurse (P), who could not identify “which nurses she was critical of at which facility,” “any specific nurse” or staff member who violated the standard of care, “any specific facts of assessing, diagnosing, planning, interventions and evaluations that she was actually critical of,” or any specific “place in the medical record” showing the claimed failures. On appeal, the court held that the trial court properly performed its gatekeeping role because expert testimony must be both relevant and reliable, and P’s opinions were “not based on sufficient facts and did not reflect a reliable application of the principles and methods to the facts of this case as required under MRE 702.” Plaintiff had “‘failed to provide any support that [her] opinions have any basis in fact[.]’” Because expert testimony was required to establish “‘the standard of care and a breach of that standard as well as causation,’” and plaintiff’s only expert was properly excluded, the court held that summary disposition under MCR 2.116(C)(10) was warranted. It also declined to disturb the refusal to allow a substitute expert after discovery because plaintiff abandoned that issue and, in any event, showed no abuse of discretion. Affirmed.