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Cruz-Vázquez v. Mennonite General Hospital, Inc.

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Before Torruella, Lipez and Howard, Circuit Judges.

In this action filed pursuant to Puerto Rico’s medical malpractice law, Articles 1802 and 1903 of the Puerto Rico Civil Code, P.R. Laws Ann. tit. 31, §§ 5141-42, and the federal Emergency Medical Treatment and Active Labor Act (“EMTALA”), 42 U.S.C. § 1395dd, the district court excluded the testimony of the plaintiffs’ lone expert witness at trial. As a result of the court’s ruling, the plaintiffs failed to offer proof on crucial elements of their case, and the district court consequently granted judgment as a matter of law for the defendants. The plaintiffs appeal, arguing that the district court abused its discretion when it excluded the expert testimony and that its award of judgment for the defendants must be vacated. We agree.

I.

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