Juan Hernández-Sánchez, et al. v. Hospital San Cristóbal, et al.

Summary

The United States District Court for the District of Puerto Rico granted defendants’ motions in limine to exclude plaintiffs’ expert witness, Dr. Edwin Miranda Aponte, in an action involving EMTALA and medical malpractice claims. The court found that Dr. Miranda lacked sufficient qualifications and that his opinions were unreliable, conclusory, contradictory, and unsupported by an established standard of care or reliable methodology. The court entered the Memorandum and Order on March 18, 2026.

Holdings

1. Dr. Miranda's proposed expert testimony was inadmissible under Federal Rule of Evidence 702 because the record did not establish that his specialized knowledge would assist the jury on the surgical-timing and medical-negligence issues, and his qualifications and current medical knowledge were inadequate for those issues.
2. Dr. Miranda's medical-malpractice opinions were inadmissible because his report did not identify the applicable standard of care or provide a reliable basis for concluding that Defendants deviated from it.
3. Dr. Miranda's EMTALA opinions were inadmissible because they were conclusory and mutually contradictory, and his own report showed that the patient's screening and stabilization claims were unsupported.

Questions Presented

1. Whether Dr. Miranda was qualified under Federal Rule of Evidence 702 to provide expert testimony concerning the alleged delay in surgery and the applicable medical standard of care.
2. Whether Dr. Miranda's report and testimony were based on sufficient facts and reliable principles and methods and reliably applied those principles and methods to the facts.
3. Whether Dr. Miranda's opinions supported Plaintiffs' EMTALA screening and stabilization claims.

Disposition

other