Charles L. Daniels II, Individually; Charles L. Daniels II, on Behalf of Payton Daniels, a Minor; And Charles L. Daniels II, as Special Administrator of the Estate of Harmony Lynn Daniels v. C. Wayne Lyle, M.D.; C. Wayne Lyle, M.D., P.A.; Medical Services Group, Ltd.; Baptist Health; And Diamond Risk Insurance LLC
2025 Ark. App. 197
Ark. Ct. App.2025Background
- Harmony Daniels died of a pulmonary embolism (PE) due to deep vein thrombosis (DVT) after being discharged from Baptist Health Little Rock, where Dr. Lyle diagnosed her with DVT and prescribed an anticoagulant.
- Her husband, Charles L. Daniels II, brought a medical malpractice suit against Dr. Lyle, related medical entities, and Baptist Health, alleging they failed to warn Harmony that her DVT was life-threatening.
- Daniels intentionally pleaded his case under the "common knowledge" exception, arguing that no expert testimony was needed to establish negligence, and disclaimed theories requiring such testimony.
- The defendants moved for summary judgment, arguing the case required expert testimony under Arkansas’s medical malpractice statute, citing expert affidavits attesting to their compliance with the standard of care.
- The circuit court granted summary judgment to defendants, finding that the applicable standard of care and causation were not matters of common knowledge and that Daniels failed to provide required expert proof.
- On appeal, Daniels argued the wrong burden of proof was applied, and expert testimony was unnecessary.
Issues
| Issue | Plaintiff’s Argument | Defendant’s Argument | Held |
|---|---|---|---|
| Is the alleged negligence a matter of common knowledge? | Daniels: Yes, so no expert needed | Defendants: No, expert testimony required | Not common knowledge; expert needed |
| Can a plaintiff avoid expert requirement under Ark. Code Ann. § 16-114-206 by pleading common knowledge? | Daniels: Yes, can plead only under first sentence of statute | Defendants: No, full statute sets standard; all elements must be common knowledge | Statute must be read as whole; expert required |
| Did the court apply the wrong burden of proof in granting summary judgment? | Daniels: Circuit court wrongly used higher burden (for expert cases) | Defendants: Correct application—statute governs; expert proof needed unless common knowledge | No error in burden applied; summary judgment proper |
| Do the defense’s expert affidavits establish the standard of care not being common knowledge? | Daniels: Claims common knowledge exception applies | Defendants: Expert affidavits show standard/proximate cause not lay issues | Agreed with defendants; expert proof necessary |
Key Cases Cited
- Lanier v. Trammell, 207 Ark. 372 (1944) (expert testimony not required if negligence is within common knowledge; distinguished as predating statute)
- Rice v. Tanner, 363 Ark. 79 (2005) (summary judgment standard under Arkansas law)
- Taylor v. Landherr, 101 Ark. App. 279 (2008) (medical negligence claims generally require expert testimony unless common knowledge applies)
- Stewart v. Deaton, 2021 Ark. App. 73 (2021) (statutory burden of proof in medical malpractice)