Croft v. Arizona Board of Dental Examiners
In Croft v. Arizona Board of Dental Examiners, 157 Ariz. 203, 209-10, 755 P.2d 1191, 1197-98 (App. 1988) the Court determined that expert testimony was not required to independently establish the applicable standard of care in a disciplinary proceeding conducted by the Arizona State Board of Dental Examiners when a dentist was charged with providing inadequate treatment.
The Court reasoned that, as distinct from a malpractice case tried to a jury or a court, the decisions in an administrative disciplinary proceeding against a professional licensee are made by a board comprised of individuals who presumably have knowledge of the applicable standard of care. Id.