Is it a "rare" medical malpractice case in which no expert medical testimony is required?

MultiRegion, United States of America

The following excerpt is from Sitts v. U.S., 811 F.2d 736 (2nd Cir. 1987):

In sum, in the view of the New York courts, the medical malpractice case in which no expert medical testimony is required is "rare." See Charlton v. Montefiore Hospital, 45 Misc.2d at 155, 256 N.Y.S.2d at 222.

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