so distinctly related to some science, profession, or occupation as to be beyond the ken of the average layperson,” the plaintiff must proffer expert testimony to establish the relevant standard of care. Id. Some courts have found that “expert testimony is generally necessary for claims of negligent training and supervision of police officers.” Robinson v. District of Columbia, Nos. 03-1455, 03-1456(RCL), 2006 WL 2714913, at *8 (D.D.C. Sept. 22, 2006); see also Briggs v. Wash. Met. Area Trans. Auth., 481 F.3d 839, 845-46 (D.C.Cir.2007) (noting “that expert testimony is routinely required in negligence cases which involve issues of safety, security, and crime prevention”) (internal quotation marks and citation omitted); Cotton v. District of Columbia, 541 F.Supp.2d 195, 207 (D.D.C.2008) (<HOLDING>). However, this Circuit has clarified that
holding that plaintiffs treatmentbased claim which focused on medical malpractice was insufficient notice of subsequent negligent supervision argument holding claim that negligent supervision caused assault was health care liability claim because it was inseparable from the health care and nursing services provided holding that the plaintiffs proffering of an expert witness without articulating a standard of care was insufficient to withstand summary judgment on a common law negligent supervision claim recognizing that a defendant physicians own practice was at least some evidence of the standard of care and concluding that the case was properly submitted to the jury notwithstanding the plaintiffs failure to call an independent expert on the standard of care holding that section 4149 did not apply to the plaintiffs state law claims of breach of duty to protect foster care children from harm and of negligent supervision negligent entrustment and negligent failure to warn