13-1118. Circumstantial evidence of medical negligence
("Res ipsa loquitur").
To prove negligence, the patient need not prove
specifically what _________________1 did or failed to do
that was negligent.
The patient may prove _______________'s1 negligence by
proving each of the following propositions:
1. that the injury or damage to the patient was
proximately caused by (the name of the
instrumentality or occurrence) which was
___________________'s1 responsibility to manage
and control; and
2. that the event causing the injury or damage to the
patient was of a kind which does not ordinarily
occur in the absence of negligence on the part of
the _____________________1 in control of [the
instrumentality] or [that portion of the
procedure].
[Propositions (1) or (2) must be proved by the
testimony of a doctor testifying as an expert.]
If you find that each of these propositions has been
proved, then you may, but are not required to, find that
__________________1 was negligent.
If, on the other hand, you find that either one of
these propositions has not been proved or, if you find,
notwithstanding the proof of these propositions, that
________________1 used ordinary care for the safety of
others in [his] [her] control and management of the
(instrumentality or occurrence) then the evidence would not
support a finding of negligence.
FOOTNOTE
1. Insert the name of the party against whom the
claim is asserted.
DIRECTIONS FOR USE
The names of the various individuals and the name or
description of the instrumentality or occurrence should be
inserted in the appropriate blanks. Care should be used
that the correct names are placed in the various blanks.
What was previously labeled res ipsa loquitur is
applicable in a medical negligence action. The fact that
there is other evidence of the specific cause of the injury
does not preclude the use of this instruction. Mireles v.
Broderick, 117 N.M. 445 (1994). Exclusive control by the
defendant, of the instrumentality or circumstance at issue
is not a prerequisite for its use. Mireles v. Broderick,
117 N.M. 445 (1994), Trujeque v. Service Merchandise
Company, 117 N.M. 388, 872 P.2d 361 (1994). As a factual
matter, two or more persons may conceivably share
responsibility of the management of the object, activity, or
circumstances at issue. Expert testimony is not necessary
where propositions 1 or 2 are within the common knowledge of
a lay person.
[Approved, effective August 1, 1999.]
COMMITTEE COMMENT
Res ipsa loquitur is an appropriate instruction in a
medical negligence case. Mireles v. Broderick, 117 N.M.
445, 874 P.2d 962 (1994). The circumstantial evidence of
medical negligence instruction has been drafted in response
and is phrased in lay terms. All arcane, magic and "sacred"
language, including even "res ipsa", have been eliminated.
Res ipsa is a rule of circumstantial negligence and
therefore has been characterized as such.
Mireles, and Trujeque v. Service Merchandise Company,
117 N.M. 388, 872 P.2d 361 (1994), indicates that exclusive
control of the instrumentality or circumstances giving rise
to the injury is not a prerequisite for utilizing this
instruction. Consequently the exclusivity requirement has
been eliminated and the requirement of management and
control is substituted in its place.
Under this instruction, a number of different persons
might have different responsibilities as to the same
patient, but if two or more physicians have the
responsibility for managing one facet of an operative
procedure, i.e., the padding of an eye or an elbow or even
share in that control, then there is no reason under the
existing case law and the principles of Bartlett and
Section 41-3A-1 NMSA 1978 why the doctrine of res ipsa does
not apply in those instances to both physicians.