Betty Callens v. Episcopal Foundation of Jefferson County d/b/a St. Martin's In-The-Pines (Appeal from Jefferson Circuit Court: CV-21-902704)., 422 So.3d 88

Betty Callens, age 81, suffered multiple left hip injuries and surgeries, including complications during rehabilitation after hip-replacement surgery.
Callens was transferred to St. Martin's In-The-Pines for rehab, where a nurse allegedly caused a third hip injury during a routine bath.
Callens filed suit against Brookdale and St. Martin's for negligence, wantonness, battery, and medical malpractice.
St. Martin’s moved for summary judgment, arguing Callens provided no supporting expert medical testimony on standard of care or causation.
The trial court granted summary judgment to St. Martin’s (but not Brookdale), finding Callens’s lack of expert testimony fatal to her claims.
On appeal, Callens argued her claims involved routine care comprehensible to laypeople, not requiring expert testimony.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Need for Expert Testimony	Claims involved routine, custodial care, not requiring expert testimony.	Care at issue was medical/complex, thus requiring expert testimony.	Expert testimony required because care for Callens's condition is not routine and outside lay knowledge.
Applicability of "Layman Exception"	Injury was obvious, so breach could be understood by lay juror.	Circumstances (multiple surgeries, immobilizer device) were complex and not within lay understanding.	Exception does not apply; lay jurors could not assess standard of care for Callens's circumstances.
Sufficiency of Defendant's Expert (Britton)	Britton not qualified due to possible administrative role during preceding year.	Britton’s affidavit established hands-on nursing experience during relevant time.	Record showed Britton qualified; affidavit allowed.
Burden at Summary Judgment	Burden on defendant to establish standard of care before burden shifts.	Defendant need only show plaintiff failed to support essential element (expert testimony).	Burden was properly on Callens to produce expert testimony once St. Martin’s moved for summary judgment.

Pruitt v. Zeiger, 590 So. 2d 236 (Ala. 1991) (expert testimony required in medical malpractice to prove standard of care, breach, and causation)
Tuscaloosa Orthopedic Appliance Co. v. Wyatt, 460 So. 2d 156 (Ala. 1984) (layman exception for expert testimony in medical-malpractice cases)
Lyons v. Walker Reg'l Med. Ctr., 791 So. 2d 937 (Ala. 2000) (requirement of expert testimony in medical negligence cases unless exception applies)
Ex parte HealthSouth Corp., 851 So. 2d 33 (Ala. 2002) (clarified the layman exception regarding when expert testimony is unnecessary)
Allred v. Shirley, 598 So. 2d 1347 (Ala. 1992) (enumerates exceptions to expert testimony requirement in malpractice)
Collins v. Herring Chiropractic Ctr., LLC, 237 So. 3d 867 (Ala. 2017) (reformulation of layman exceptions)
Rivard v. University of Alabama Health Servs. Found., P.C., 835 So. 2d 987 (Ala. 2002) (expert testimony must establish causation in malpractice cases)