Rhonda Kay Armour v. Southeast Alabama Medical Center, No. SC-2025-0517, 2026 WL 785335 (Ala. Mar. 20, 2026). The Court (Stewart, C.J., and Shaw, Bryan, and McCool, JJ., concur) (plurality opinion) affirms the Houston Circuit Court’s summary judgment in favor of Southeast Alabama Medical Center (“SEAMC”) in a medical-malpractice action arising from the amputation of Rhonda Armour’s left leg. The issue on appeal was whether Armour presented substantial evidence of proximate causation through qualified expert testimony. Ms. **6-7.
The Court reiterates that a plaintiff in a medical-malpractice action “ordinarily must present expert testimony from a 'similarly situated health-care provider' as to ... 'a proximate causal connection between the [defendant's] act or omission constituting the breach and the injury sustained by the plaintiff.'” Ms. **22-23, quoting Lyons v. Walker Reg'l Med. Ctr., 791 So. 2d 937, 942 (Ala. 2000).
Plaintiff’s expert, a hospitalist, presented testimony that Dr. Barkley breached the standard of care for a hospitalist and that those breaches probably led to plaintiff’s leg needing to be amputated. Ms. *9. SEAMC argued that plaintiff’s expert’s causation testimony rested upon an assumption that had a vascular surgeon been consulted, said vascular surgeon would have undertaken some intervention that would have prevented plaintiff’s eventual injury. Ms. *20. However, plaintiff failed to provide any expert testimony establishing that a vascular surgeon would have undertaken such an intervention. Ms. *9.
The Court therefore holds that plaintiff’s expert’s testimony as to causation “depended on speculation regarding treatment plaintiff would have received from a medical specialist that is outside [plaintiff’s expert’s] area of expertise.” Ms. *22. “Armour did not submit any testimony from a vascular surgeon to close this gap in her evidence of medical causation.” Id.
SEAMC, on the other hand, provided testimony from a vascular surgeon who “refuted [plaintiff’s causation expert]’s speculation” by testifying he would have not taken any action for treatment of Armour’s condition. Ms. **23-25.Therefore, “[e]ven if it is assumed that Dr. Barkley breached the standard of care…by failing to consult a vascular surgeon to determine a treatment regimen for Armour’s condition, the only competent evidence submitted by either party dictates that those breaches of the standard of care would not have affected the outcome of the case.” Ms. *25. “In other words, Armour did not establish a causal link between Dr. Barkley’s alleged breaches of the standard of care and the injury she sustained.” Id. The Court further notes that expert testimony must be viewed as a whole. When considered in full, the alleged causal link relied on treatment decisions outside the expert’s field. Ms. **21-22.
The Court explains because plaintiff’s causation expert was not a vascular surgeon – i.e., a similarly situated health care provider as required by Ala. Code § 6-5-548 – plaintiff’s expert could not testify as to what interventions a vascular surgeon would have undertaken that would have prevented plaintiff’s injury, and, therefore, the expert’s opinion was insufficient to establish proximate causation. Ms. **22-23.
Accordingly, the Court holds that Armour failed to present substantial evidence of proximate causation and affirms the summary judgment. Ms. *26.