that Dr. Dirksmeier and the Veterans Affairs Medical Center misrepresented Dr. Dirksmeier’s level of experience and gave Wooding the impression that he had more experience performing surgeries than he actually had. Accordingly, to make out a claim for intentional misrepresentation, Wooding was required to show that his injuries were proximately caused by his reliance on Dr. Dirksmeier’s alleged misrepresentations. See Bortz v. Noon, 729 A.2d at 560. Thus, in this case, Wooding must show that his injuries were caused by Dr. Dirksmeier’s alleged lack of experience, and not simply a result of the surgery. This requires expert testimony, because the causal link is not obvious to a lay person. Cf. Quinby v. Plumsteadville Family Practice, Inc., 589 Pa. 183, 907 A.2d 1061, 1070-71 (2006) (<HOLDING>). Wooding concedes that the expert he has
holding expert testimony is generally required to establish proximate cause in medical malpractice cases recognizing that even when a prisoner files suit under section 1983 alleging medical malpractice against prison medical officials medical malpractice does not become a constitutional violation merely because the victim is a prisoner recognizing that a plaintiff must produce a medical expert to testify as to causation in all but the most selfevident medical malpractice actions holding that nurse who is familiar with the standard of care at another similar hospital can qualify by experience to testify as a medical expert in a medical malpractice action holding that a north carolina rule requiring an expert certification in a medical malpractice case applied in a federal tort claims act case sounding in medical malpractice brought in federal court