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Lynne N. Nahmani

Co-Chair, Long-Term Care Liability Practice

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Portrait of Lynne N. Nahmani

As a supervising attorney for the Health Care Liability Practice, Lynne coordinates and oversees the work of the attorneys who handle cases throughout eight New Jersey counties. Lynne's role is vital to ensuring that client matters are handled promptly, professionally and effectively. Lynne also serves as the co-chair of the Long-Term Care Liability Practice Group.

Lynne has been a trial attorney for more than 35 years and has litigated hundreds of cases in the state courts of New Jersey and Pennsylvania, many to verdict and directed verdict in favor of her clients. She has provided legal counsel to physicians, hospitals, nurses, allied health professionals, dentists, nursing homes and physician practices.

Lynne received a Bachelor of Science degree from Sargents College of Health and Rehabilitation Sciences at Boston University in 1985. After completing internships at Thomas Jefferson University Hospital, The Children's Hospital of Philadelphia and Eugenia Hospital, Lynne became a licensed occupational therapist. She later enrolled at Temple University School of Law to pursue a career that combined her health care education with the practice of law.

Lynne has spent her legal career defending practitioners and facilities in the health care industry.

    • Temple University Beasley School of Law (J.D., 1989)
    • Boston University (B.S., 1985)
    • New Jersey, 1989
    • Pennsylvania, 1989
    • U.S. District Court Eastern District of Pennsylvania
    • AV® Preeminent™ by Martindale-Hubbell®
      The Martindale-Hubbell rated attorney list is issued by Internet Brands, Inc. A description of the selection methodology can be found here. No aspect of this advertisement has been approved by the Supreme Court of New Jersey.
    • The Best Lawyers in America©, Litigation – Health Care (2024-2027)
      The Best Lawyers list is issued by Woodward & White. A description of the selection methodology can be found here. No aspect of this advertisement has been approved by the Supreme Court of New Jersey.
    • New Jersey Super Lawyers (2006-2007)
      The Super Lawyers list is issued by Thomson Reuters. A description of the selection methodology can be found here. No aspect of this advertisement has been approved by the Supreme Court of New Jersey.
    • South Jersey Magazine, Top Lawyer 2009
    • American Bar Association
    • Camden County Bar Association
    • Diversity Law Institute
    • Federation Allied Jewish Appeal
    • Perelman Jewish Day School, Board Member (2013-2016)
    • Pennsylvania Bar Association
    • The Trial Law Institute
    • Trial Attorneys of New Jersey, Board Member (2012-present)
    • Long Term Care Litigation and the Covid-19 Pandemic: Injury and Immunity, New Jersey Institute for Continuing Legal Education, June 1, 2020
    • What is Your Case Worth?, Marshall Dennehey Health Care and Health Law Seminar, November 9, 2017
    • New Jersey Case Law Update, Health Care Law Seminar, Marshall Dennehey, November 9, 2016
    • Avoiding and Defending Nursing Home Litigation, American College of Health Care Administrators 50th Annual Convocation & Exposition, April 20, 2016
    • Mock Trial: Lessons from the Bar and Risk Management, American Professional Agency, Inc., March 23, 2016
    • Affidavit of Merit, Experts and the Net Opinion Rule Seminar, New Jersey State Bar Association Summer CLEFest, August 14, 2015
    • Sex and the Facility: Understanding and Reducing Liabilities, American Health Care Association/National Center for Assisted Living Annual Conference, October 5, 2014, Washington, D.C.
    • Sex and the Facility - Starring the Defense, 2013 Trends in Health Care and Health Law Seminar, Marshall Dennehey, November 7, 2013 
    • Long-Term Care, Hospicomm, April 4, 2012
    • Nursing Home Litigation – How to Handle and Defend a Case, Allied World Assurance Company, January 2012
    • When You Are First Sued, What to Do and What Not to Do and the Processes of a Medical Negligence Claim, University of Medicine and Dentistry of New Jersey, program for medical residents and physicians, Spring 2010
    • Annual Seminar for Clients and Risk Managers, Princeton Insurance Company
    • Risk Management and Dental Claims, Eastern Dentists Insurance Company
    • Mock Trial Demonstration, South Jersey Medical Office Managers Society, Conventus Insurance Company
    • Seminars given at local hospitals for interns and residents, CME credits
    • "Med Mal Litigation and Social Media Records: Where is New Jersey Headed?"New Jersey Law Journal, May 19, 2014
    • "Doctor's Personal Characteristics Not Relevant to Claims of Informed Consent," The Redwoods Group Dentists Insurance Program, Monthly Article, January 2002 and Defense Digest, 2001-10, Vol. 7, No. 5
    • "Defending the Discovery Rule," Defense Digest, Spring 1993
    • Successfully defended a chiropractor with a directed verdict on informed consent and a no cause, 7-0, on standard of care. Plaintiff claimed the defendant was negligent in failing to obtain a MRI before adjusting the lumbar spine with a differential diagnosis which included a herniated or bulging disc. Plaintiff claimed increased risk of harm for foot drop, surgery, pain and suffering and alteration in work and life enjoyment.
    • Secured a directed verdict in a subacute rehab case. The plaintiffs claimed their father, who suffered from dysphagia, was negligently left unattended to choke and die in his room by the nursing staff while eating breakfast. At the close of plaintiff’s case, three motions for directed verdict were made. The court eventually agreed that the plaintiffs had not met their burden on causation with the expert testimony.
    • Represented general surgeon called in to perform emergency laparoscopic appendectomy. Five days after uneventful surgery and discharge, plaintiff is transported via medivac to a tertiary care facility for an emergent splenectomy. Defense successfully utilized literature and expert testimony both on direct and cross examination that, however rare, splenic injury can occur after laparoscopic procedure due to the insufflation of the abdomen in the presence of adhesions. Jury returned a verdict for the defense.
    • Represented mental health institution whereby a depressed and bipolar 28-year-old father and husband was receiving outpatient treatment when he locked himself in his truck, covered himself with gasoline and struck a match, only to survive. Plaintiff suffered second and third degree burns over more than 70 percent of his body. He lived severely disfigured with no facial features and no arms below the elbows. Plaintiff claimed defendant facility failed to recognize plaintiff's suicide risk and was ill-equipped to handle patients with a dual diagnosis. Successfully defended at mediation.
    • Jury returned a defense verdict for general surgeon who took an 89-year-old to surgery for treatment of diverticulitis and made the medical judgment not to remove the affected colon once the patient's vital signs took a turn for the worse during surgery. Decision to get the patient out of surgery and treat with antibiotics was not successful as the patient died within 48 hours. Defense convinced the jury that the surgeon was not negligent, rather, he exercised medical judgment in making this decision.
    • Defendant hospital granted summary judgment in a case where it was alleged the hospital failed to provide an appropriate and complete background check subsequent to employing a nurse who was later accused of killing patients within the institution. Claims dismissed on jurisdiction and lack of patient-physician relationship.
    • Obtained a defense directed verdict in a nursing home trial against a well-known plaintiffs' firm. Allegations included violations of the NJ Nursing Home statute with damages for a Stage IV decubiti, loss of dignity and requests for statutory counsel fees. Testimony from ex-employees and family members was introduced to suggest the resident was left for many hours unattended, double diapered and dirty. Plaintiffs never came off a $1 million dollar demand.

Results

Thought Leadership

The Quarterly Dose

From Bedside to Bar

August 26, 2026

Lynne N. Nahmani, Esq. Former Occupational Therapist For the Love of Medicine! After more than three decades defending health care professionals in medical malpractice cases, I still harken back to my undergraduate education as an occupational therapist. My education focused on anatomy, physiology, human behavior, and physical and cognitive development; disciplines that have shaped every single legal case I have defended. The competencies acquired are closely aligned, as the scientific analysis reflected in a S.O.A.P. note parallels the legal reasoning process. As lawyers, we must recognize the Subjective and Objective case facts, perform a legal Assessment, and develop a Plan for defense. Both professions require critical thinking, careful investigation, and a commitment to solving complex problems. Whether serving a patient or a client, the goal is the same: provide guidance and support for their particular problem. Each problem requires a scientific exercise into the underlying medicine. By understanding the medical issues involved, we are better equipped to build a strong defense, explain complex concepts to a jury, and help our clients make informed decisions about the risks, options, and strategies available for achieving the best possible outcome. Susan A. Kostkas, Esq. Registered Nurse When people ask what I do for a living, I often describe myself as a “nurse who went to law school.” Caring for others has always been a natural part of who I am. Inspired by my mother, a nurse, I began working in nursing homes as a dietary aide during high school and later as a nurse’s assistant while in college. I went on to practice as a nurse at the bedside for ten years, primarily in cardiac care, including time before, during and after law school. My nursing experience continues to influence the way I practice law every day. As a nurse, I learned to assess complex situations, prioritize competing demands, solve problems under pressure, and collaborate effectively with multidisciplinary teams. Those same skills are invaluable in litigation, where strategic decision-making, careful analysis, and teamwork are critical to achieving successful outcomes. My health care background also gives me a unique perspective when reviewing medical records and evaluating clinical issues. Being able to understand medical conditions and health care concepts helps me identify key issues related to liability, causation, and damages. Most importantly, nursing taught me the value of the human side of advocacy. The skills of active listening, empathy, and conflict resolution remind me to slow down amid the demands of litigation and focus on my client. Often, the most important insights into a case come directly from them. These same skills also help me better understand the motivations of plaintiffs and their counsel, allowing me to develop thoughtful, effective defense strategies.

The Quarterly Dose

New Leverage for Defendants: Burckhardt’s Impact on New Jersey Nursing Home Act Litigation

June 11, 2026

In a unanimous, unpublished opinion issued on February 24, 2026, the New Jersey Superior Court, Appellate Division, affirmed the dismissal of claims against a rehabilitation facility based on the plaintiffs’ failure to prove proximate causation—an essential element of negligence claims as well as claims brought under New Jersey’s Nursing Home Act (NHA). Although unpublished, Burckhardt v. Advanced Subacute Rehabilitation Center at Sewell, LLC provides important guidance for defendants facing nursing home malpractice and Resident-Rights Act litigation. Background of the Case The decedent, Burckhardt, was a 72-year-old resident at Advanced Subacute Rehabilitation Center at Sewell (Advanced). He had numerous medical conditions, including encephalopathy, diabetes mellitus, hypertension, urinary tract infection, respiratory failure, dysphagia, and required assistance with activities of daily living, including eating. The plaintiffs alleged that Advanced failed to follow Burckhardt’s care plan by leaving him alone in his room while eating and failing to follow his care plan.  During that time, he choked and required emergency medical intervention and was hospitalized.  Burckhardt suffered cardiac arrest and died two days later. His children, the Estate representatives, filed suit against Advanced, alleging negligence and violations of the NHA based on the alleged failure to appropriately “monitor” him during meals as care planned for. Trial Court’s Ruling After five days of testimony, the trial court granted a directed verdict in favor of Advanced, dismissing all claims. The court concluded that the plaintiffs failed to present sufficient evidence of proximate causation. Specifically, Advanced argued, previously via summary judgment and again at trial, that neither of the plaintiffs’ medical experts offered sufficient testimony establishing that the alleged lack of staff presence was a “but-for” or “substantial factor” cause of Burckhardt’s injuries and death, as required under New Jersey law. The trial court agreed. It emphasized that the plaintiffs’ nursing expert, Bonnie Tadrick, testified only as to the applicable standard of care and an alleged failure to monitor, but admittedly did not offer an opinion on causation. The plaintiffs’ physician expert, Dr. Hood,  testified about the mechanics of choking and identified choking as the cause of death. However, Dr. Hood failed to opine that any conduct by the Advanced staff caused, increased the risk or worsened the choking episode. Without expert testimony linking the alleged breach of care to the outcome, the court found the plaintiffs’ proofs legally insufficient and dismissed the case. Appellate Division’s Analysis The Appellate Division affirmed, carefully analyzing the causation requirements for both negligence and NHA claims. The court held that the Estate failed to establish the essential causal link between any alleged lapse in care and Burckhardt’s injury. With respect to Nurse Tadrick, the court noted that while she testified about the standard of care and the need for monitoring, she admitted she was not offering a causation opinion—and could not do so under New Jersey law, which prohibits nurses from testifying about medical causation. Her testimony did not explain how staff presence in the room would have prevented the choking, altered its severity or the ultimate outcome. As to Dr. Hood, the Appellate Division acknowledged that he was qualified to testify on causation but found his testimony inadequate. Although he explained how choking occurs and identified it as the cause of death, he never testified that the alleged absence of staff caused the choking or was a substantial factor in producing the injury. He also never opined that the staff failed to timely respond to the alleged incident. The court stressed that to reach a jury, plaintiffs were required to present evidence from which a jury could reasonably conclude that the absence of staff increased the risk of harm and that earlier intervention would likely have changed the outcome. In this case, the plaintiffs failed to meet that minimal threshold. Nursing Home Act Claims and Causation The Appellate Division also squarely addressed whether NHA claims require proof of causation. The Estate argued they did not. The court rejected that argument, holding that causation is required even though the NHA does not explicitly use the word. The court reasoned that damages are, by definition, compensation for harm, and recovery without a causal connection would make little sense. The court further held that the NHA claims failed for an additional reason: the Estate did not establish a separate or distinct injury attributable to the alleged resident-rights violation. Even if causation had been established, the absence of proof that the alleged NHA violation resulted in an independent injury was fatal to the claim. Significance of Burckhardt Although unpublished, Burckhardt is a meaningful decision for defendants in nursing home litigation. The Appellate Division’s clear statement that NHA claims require proof of proximate causation—and an identifiable injury tied to the alleged statutory violation—provides defendants with a powerful basis for early motion practice. The decision supports dispositive motions at the summary judgment stage where plaintiffs’ experts fail to connect alleged care deficiencies to a specific injury. It also serves as a lesson to defense counsel to renew the dispositive motion grounds at the end of a plaintiff’s case, where appropriate.

Firm Highlights

News

106 Marshall Dennehey Attorneys Recognized in the 2027 Editions of The Best Lawyers in America® and the Best Lawyers: Ones to Watch® in America

Marshall Dennehey is proud to highlight the firm’s 106 attorneys who have been recognized in the 2027 editions of The Best Lawyers in America® and the Best Lawyers: Ones to Watch® in America. Less than 6% of all practicing lawyers in the U.S. were selected by their peers for this recognition. Additionally, four of the firm’s attorneys received the Best Lawyers® 2027 “Lawyer of the Year” awards in their respective practice areas and demographic regions. Since it was first published in 1983, Best Lawyers® has become universally regarded as the definitive guide to legal excellence. Best Lawyers lists are compiled based on an exhaustive peer-review evaluation. For more information, please visit https://www.bestlawyers.com/. OUR 2027 LAWYERS OF THE YEAR Harrisburg, PA Christopher Reeser, Personal Injury Litigation - Defendants Kacey Wiedt, Workers Compensation Law - Employers Roseland, NJ Justin F. Johnson, Medical Malpractice Law - Defendants Leonard Leicht, Personal Injury Litigation - Defendants   OUR 2026 BEST LAWYERS IN AMERICA Philadelphia, PA Nicholas D. Bowers, Personal Injury Litigation - Defendants Josh J. T. Byrne, Professional Malpractice Law - Defendants Jefferey J. Chomko, Insurance Law James H. Cole, Insurance Law John J. Delany III, Personal Injury Litigation - Defendants Laurianne Falcone, Personal Injury Litigation - Defendants John P. Gonzales, Employment Law - Management John Hare, Appellate Practice Daniel D. Krebbs, Personal Injury Litigation - Defendants Michele Punturi, Workers' Compensation Law - Employers Bradley D. Remick, Product Liability Litigation - Defendants Andrea Cicero Rock, Workers' Compensation Law - Employers Robin M. Romano, Workers' Compensation Law - Employers Daniel J. Ryan, Jr., Personal Injury Litigation - Defendants Gary M. Samms, Professional Malpractice Law - Defendants Christopher N. Santoro, Personal Injury Litigation – Defendants; Product Liability Litigation -Defendants Josh D. Scheets, Personal Injury Litigation - Defendants Robert P. Schenk, Workers' Compensation Law - Employers Robert E. Smith, Insurance Law Robin Snyder, Litigation - Health Care Michael L. Turner, Commercial Litigation; Criminal Defense: White-Collar; Mass Tort Litigation / Class Actions - Defendants Claire Breaux Ventola, Product Liability Litigation - Defendants Pittsburgh, PA Melissa Devich Cochran, Commercial Litigation; Mass Tort Litigation / Class Actions – Defendants; Product Liability Litigation - Defendants  John F. Deasy, Personal Injury Litigation – Defendants; Product Liability Litigation - Defendants Daniel W. Deitrick, Workers' Compensation Law - Employers Douglas C. LaSota, Litigation - Construction; Mass Tort Litigation / Class Actions - Defendants Joseph V. Lesinski, Product Liability Litigation – Defendants   Christian D. Marquis, Personal Injury Litigation - Defendants Patricia A. Monahan, Insurance Law; Litigation - Insurance Patrick T. Reilly, Commercial Litigation; Mass Tort Litigation / Class Actions – Defendants; Product Liability Litigation - Defendants Brett C. Shear, Medical Malpractice Law - Defendants Teresa O. Sirianni, Education Law; Employment Law – Management; Litigation - Labor and Employment Stuart Sostmann, Product Liability Litigation – Defendants Danielle M. Vugrinovich, Mass Tort Litigation / Class Actions - Defendants Scranton, PA Sarah E. Argo, Litigation - Insurance Michael J. Connolly, Personal Injury Litigation – Defendants; Professional Malpractice Law - Defendants Matthew Keris, Litigation - Health Care; Medical Malpractice Law - Defendants John T. McGrath, Jr., Insurance Law; Medical Malpractice Law – Defendants; Product Liability Litigation - Defendants William J. McPartland, Insurance Law John R. Nealon, Product Liability Litigation - Defendants Victoria Scanlon, Health Care Law; Litigation - Health Care; Medical Malpractice Law - Defendants Michael A. Sebastian, Workers' Compensation Law - Employers Thomas A. Specht, Insurance Law; Litigation - Insurance Suzanne Tighe, Litigation Insurance Harrisburg , PA Casey Alan Coyle, Administrative/Regulatory Law; Appellate Practice; Commercial Litigation Brittany E. Bakshi, Personal Injury Litigation - Defendants Shannon P. Fellin, Workers' Compensation Law - Employers Allison Krupp, Insurance Law John R. Ninosky, Litigation – Insurance; Personal Injury Litigation - Defendants Christopher Reeser, Personal Injury Litigation - Defendants Kacey Wiedt, Workers' Compensation Law – Employers King of Prussia, PA  Michael L. Detweiler, Construction Law Joseph L. Hoynoski III, Medical Malpractice Law - Defendants Gregory J. Kelley, Construction Law, Litigation - Construction Anthony Natale III, Workers' Compensation Law - Employers Francis X. Wickersham, Workers' Compensation Law - Employers A. Judd Woytek, Workers' Compensation Law – Employers Erie, PA Patrick M. Carey, Personal Injury Litigation - Defendants Joel M. Snavely, Health Care Law; Insurance Law New Haven, CT Michael Wrona, Commercial Litigation, Litigation - Bankruptcy  Mount Laurel, NJ David D. Blake, Litigation - Insurance Barbara Davis, Personal Injury Litigation - Defendants Lynne Nahmani, Litigation - Health Care John H. Osorio, Personal Injury Litigation - Defendants John L. Slimm, Legal Malpractice Law – Defendants; Professional Malpractice Law – Defendants Roseland, NJ Robert T. Evers, Medical Malpractice Law - Defendants Justin F. Johnson, Medical Malpractice Law - Defendants Julia Klubenspies, Medical Malpractice Law - Defendants Leonard C. Leicht, Personal Injury Litigation - Defendants Patricia M. McDonagh, Appellate Practice Sunny Sparano, Litigation - Construction Randall S. Watts, Health Care Law New York, NY Tonya M. Lindsey, Medical Malpractice Law - Defendants Tampa, FL Michael Archibald, Personal Injury Litigation - Defendants Lindsay G. McCormick, Litigation – Construction Orlando, FL Thomas F. Brown, Personal Injury Litigation - Defendants Dante C. Rohr, Commercial Litigation Fort Lauderdale, FL Kimberly Kanoff Berman, Appellate Practice Patrick M. Delong, Personal Injury Litigation – Defendants Jacksonville, FL  Heather Byrer Carbone, Workers' Compensation Law - Employers Linda Wagner Farrell, Workers' Compensation Law - Employers Elizabeth B. Ferguson, Litigation - Construction James P. Hanratty, Personal Injury Litigation – Defendants Wilmington, DE Sarah B. Cole, Litigation - Insurance Benjamin K. Durstein, Workers' Compensation Law - Employers Maria R. Granaudo, Medical Malpractice Law - Defendants  Keri L. Morris-Johnston, Workers' Compensation Law - Employers Cincinnati, OH Timothy B. Schenkel, Personal Injury Litigation - Defendants David E. Williamson, Personal Injury Litigation - Defendants Cleveland, OH Vincent E. Cononico, Litigation – Insurance, Personal Injury Litigation - Defendants Jillian L. Dinehart, Personal Injury Litigation - Defendants David J. Fagnilli, Insurance Law Jason P. Ferrante, Health Care Law, Litigation - Health Care Andrew H. Isakoff, Transportation Law Leslie M. Jenny, Litigation - Health Care; Medical Malpractice Law – Defendant OUR 2026 BEST LAWYERS: ONES TO WATCH Jacksonville, FL Sean J. Reeves, Personal Injury Litigation – Defendants; Product Liability Litigation - Defendants Orlando, FL Carolin A. Pacheco, Insurance Law Mount Laurel Stacey Gorin, Insurance Law Melville, NY Kimberly Gitlin, Personal Injury Litigation – Defendants Matthew A. Gray, Insurance Law; Personal Injury Litigation - Defendants Philadelphia, PA Holli K. Archer, Health Care Law; Medical Malpractice Law – Defendants; Professional Malpractice Law Emily Pritchyk, Commercial Litigation; Product Liability Litigation – Defendants Pittsburgh, PA Taylor E. Kosko, Mass Tort Litigation / Class Actions – Defendants; Personal Injury Litigation - Defendants Alana Staniszewski, Workers' Compensation Law - Employers Michael D. Winsko, Product Liability Litigation – Defendants; Transportation Law King of Prussia, PA Richard Lechette, Commercial Litigation; Insurance Law, Personal Injury Litigation – Defendants

Thought Leadership

Pennsylvania Superior Court Reaffirms Liberal Pleading Standard in Medical Malpractice Actions

Legal Roundup: Pennsylvania The Pennsylvania Superior Court has reinforced a broader fact-pleading approach that may make it more difficult for health care defendants to obtain dismissal at the preliminary objection stage. In DaSilva v. Abington Memorial Hospital, the court held that the plaintiffs’ second amended complaint satisfied Pennsylvania’s fact‑pleading requirements despite the absence of individually named negligent actors. In DaSilva, the plaintiffs filed a second amended complaint alleging that Abington Memorial Hospital was directly and vicariously negligent after the patient, who was experiencing a mental health crisis, was left unattended by hospital staff, exited the emergency department, and was struck by a vehicle, suffering serious injuries. The trial court sustained the hospital’s preliminary objections and dismissed the complaint with prejudice, stating plaintiffs “failed to plead any material factual allegations in support of their claims of negligence [and] set forth vague allegations of negligence and unidentified agency.” Id. at *5. The plaintiffs appealed. On appeal, the Superior Court reversed, holding that the complaint sufficiently pled negligence and vicarious liability claims under Pa.R.C.P. 1019(a). The court concluded that allegations describing the patient’s condition, the hospital’s awareness of that condition, and the alleged failure to monitor or prevent elopement were adequate to satisfy Pennsylvania’s pleading requirements. Significantly, the court rejected the hospital’s argument that the complaint failed because it did not identify the specific employees responsible for the alleged negligence. Instead, the court found that generalized references to “emergency room staff” were sufficient to place the hospital on notice of the claims because “the names of those who performed services for the plaintiff are known to the defendant or can be ascertained during discovery.” Id. at *12 (citing Est. of Denmark ex rel. Hurst v. Williams, 117 A.3d 300, 307 (Pa. Super. 2015)). The effect of DaSilva is that plaintiffs may proceed past the pleading stage with relatively generalized allegations, particularly in cases involving institutional defendants where relevant details are uniquely within the defendant’s control. As a result, health care defendants should anticipate that challenges to claim sufficiency may be resolved in the later stages of litigation, including discovery and summary judgment.

Thought Leadership

The Ohio Supreme Court Extends Sham-Affidavit Rule to Contradictory Expert Reports

Legal Roundup: Ohio In its June 23, 2026, decision in Moore v. Mercy Medical Center, the Ohio Supreme Court upheld a trial court’s decision to strike an expert witness’s affidavit that contradicted the opinions expressed in the expert’s prior report. This case pertains to allegations of medical malpractice after plaintiff Cheri Moore gave birth to an infant in respiratory distress who required intubation. Moore alleged that a delay in ordering an emergency cesarean section resulted in the need for intubation, causing her child’s injuries. Specifically, Moore sued Dr. Meniru, who completed his first shift at 7:00 a.m. on May 28, 2015, and did not resume treating Moore until 7:00 a.m. on May 29, 2015. One of Moore’s expert witnesses authored a report stating that the doctors, including Dr. Meniru, deviated from the standard of care by not advocating for a cesarean section in the evening of May 28, 2015. Based on this report, Dr. Meniru moved for summary judgment, arguing that the alleged breach occurred during a period when he was not on duty. In response to the summary judgment motion, the plaintiff filed an affidavit from the same expert. Although the expert expressly incorporated his previous report into his affidavit, he also offered an additional opinion: that Dr. Meniru breached the standard of care by failing to begin a cesarean section within 30 minutes of receiving reports of fetal distress. Dr. Meniru filed a motion to strike the expert’s affidavit, arguing that it contradicted the opinions set forth in his prior report in violation of the sham-affidavit rule. The sham-affidavit rule applies to “a contradictory affidavit that indicates only that the affiant cannot maintain a consistent story, or is willing to offer a statement solely for the purpose of defeating summary judgment”. Moore, supra, at ¶ 19, citing Pettiford v. Aggarwal, 126 Ohio St.3d 413, 2010-Ohio-3237. The trial court granted both the motion to strike and the motion for summary judgment, and the Fifth District affirmed. The Ohio Supreme Court accepted two questions of law: (1) whether the sham-affidavit rule applies when the sworn testimony contradicts prior unsworn statements; and (2) whether an inconsistency within the affidavit goes to credibility or admissibility, justifying an order striking the affidavit. Previous rulings by the Ohio Supreme Court regarding the sham-affidavit rule have pertained to contradictions between an affidavit and sworn deposition testimony. See, e.g., Byrd v. Smith, 2006- Ohio-3455, 110 Ohio St.3d 24, 850 N.E.2d 47. However, here, the Court was asked to apply the same rule to contradictions between a sworn affidavit and an unsworn expert report. The Court held that, because Moore’s expert incorporated his prior report into his affidavit, he effectively adopted the report as part of his sworn testimony.