Smith v. Yohe

In Smith v. Yohe, 412 Pa. 94, 104-106, 194 A.2d 167, 172-173 (1963), our Supreme Court held that expert testimony was not necessary to establish a prima facie case of negligence where a physician failed to take diagnostic x-rays to rule out the possibility of fractures after an elderly patient had fallen, causing paralysis on his right side, extreme pain and obvious displacement. The Court held that the average member of a jury would have sufficient knowledge of the diagnostic value of x-rays to determine whether the physician's failure to take x-rays "evidenced a lack of judgment and care in arriving at a diagnosis." Id. at 105, 194 A.2d at 173.