Postell v. Hankla, 317 Ga. App. 86

Everett sustained a permanent brachial plexus injury at birth in 2003; Postell, as mother and next friend, sued Hankla and Southern OB-GYN Associates for medical malpractice; Postell alleged Hankla used excessive lateral traction during shoulder dystocia, breaching the standard of care; on remand, a jury found for Hankla and the trial court entered judgment; Postell appeals challenging admission of Brickman’s expert testimony and limits on cross-examining Moseley about financial interests; court held Brickman was not qualified under OCGA § 24-9-67.1(c)(2)(D) to testify on Hankla’s standard of care and that admission was reversible error; the cross-examination limitation on Moseley was within the trial court’s discretion; judgment reversed and remanded.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Brickman is qualified to testify on nurse midwife standard of care	Postell argues Brickman lacked qualification as an expert on midwife care	Hankla contends Brickman qualified via active practice or teaching	Brickman not qualified; admission reversible error
Whether the cross-examination of Moseley about financial interests was properly restricted	Postell contends cross-examination should reveal bias/financial stake	Trial court acted within discretion to limit inquiry into wealth/insurance	No abuse; limitation upheld

Hankla v. Jackson (Hankla I), 305 Ga. App. 391 (2010) (interlocutory appeal on expert testimony ruling)
Anderson v. Mountain Mgmt. Svcs., 306 Ga. App. 412 (2010) (physician expert not qualified to testify on nurse's standard of care without related supervision)
Griffin v. Bankston, 302 Ga. App. 647 (2009) (disinterested treating physician may carry weight; cross-examination limitations reversible error)
Goins v. Glisson, 163 Ga. App. 290 (1982) (insurance evidence generally inadmissible except when germane)
Dept. of Transp. v. Petkas, 189 Ga. App. 633 (1988) (consideration of witnesses’ interest in determining credibility)