Sayer v. Williams
In Sayer v. Williams, 962 P.2d 165, 167 (Wyo. 1998), a medical malpractice claim, the plaintiff contended that the substandard care she received caused her symptoms of dizziness and fatigue.
The district court ruled that by failing to provide expert testimony on causation she had failed to prove it as a matter of law and directed a verdict in favor of the defendant.
The Court upheld the ruling that expert testimony is required to satisfy causation in all but extraordinary cases of medical malpractice. Sayer, 962 P.2d at 168.