What is the test for obtaining expert testimony in a medical malpractice case?

This question was not one that required expert testimony. "Although courts have not always used the same language, the decisive consideration in determining the [necessity] of expert opinion evidence is whether the subject of inquiry is one of such common knowledge that [persons] of ordinary education could reach a conclusion as intelligently as the witness or whether, on the other hand, the matter is sufficiently beyond common experience that the opinion of an expert [is required]." (People v. Cole (1956) 47 Cal.2d 99, 103, 301 P.2d 854; see Evid. Code, 801.)