The South Dakota Supreme Court issued a split decision in *Walton v. Huron Regional Medical Center*, partially affirming and partially reversing a lower court ruling in a medical malpractice case that centered on expert witness testimony and patient monitoring standards.
Kevin Walton and his wife Julie Walton filed suit against Huron Regional Medical Center and Dr. William J. Miner, alleging that Kevin suffered a hypoxic brain injury due to the administration of high dosages of opiates and inadequate patient monitoring while he was being treated for testicular pain. The case raised important questions about medical standard of care and the admissibility of expert testimony in malpractice litigation.
The dispute arose from Kevin Walton's treatment at the medical facility, where he received opioid medications for testicular pain. According to the complaint, the medical providers allegedly administered excessive dosages of opiates and failed to properly monitor Walton's condition, resulting in oxygen deprivation to his brain and subsequent injury.
Following the discovery phase of litigation, Huron Regional Medical Center moved to exclude the testimony of Dr. Richard Adler, whom the Waltons had designated as their causation expert witness. The medical center argued that Dr. Adler's testimony did not meet the reliability standards required under South Dakota Codified Laws 19-19-702, which governs the admissibility of expert testimony in state courts. Dr. Miner subsequently joined the motion to exclude the expert witness.
The reliability standard under SDCL 19-19-702 requires that expert testimony be based on sufficient facts or data, be the product of reliable principles and methods, and that the witness has reliably applied the principles and methods to the facts of the case. This standard mirrors the federal Daubert standard and is designed to ensure that only scientifically reliable expert testimony reaches the jury.
The circuit court for the Third Judicial Circuit in Beadle County, presided over by Judge Patrick T. Pardy, initially granted the defendants' motion to exclude Dr. Adler's testimony. This ruling likely had significant implications for the plaintiffs' ability to prove causation in their medical malpractice claim, as expert testimony is typically essential in establishing the standard of care and proving that a defendant's actions caused the plaintiff's injuries.
The case was argued before the South Dakota Supreme Court on Nov. 17, 2025, with the court issuing its opinion on Jan. 28, 2026. Chief Justice Jensen authored the court's decision, which resulted in a mixed outcome for both parties.
The legal representation in the case included Daniel K. Brendtro of Hovland Rasmus & Brendtro in Sioux Falls representing the Walton plaintiffs. Mark W. Haigh of Evans, Haigh & Arndt in Sioux Falls represented Huron Regional Medical Center, while Dr. Miner was represented by Gregory J. Bernard and Corey J. Quinton of Thomas, Braun, Bernard & Burke in Rapid City.
The partial affirmance and partial reversal by the state's highest court suggests that the justices found merit in some aspects of both parties' arguments. While the specific details of which portions were affirmed or reversed are not detailed in the available court documents, such mixed rulings often involve complex issues of expert witness admissibility, evidentiary standards, or procedural matters.
Medical malpractice cases involving opioid administration and patient monitoring have become increasingly significant as healthcare providers face scrutiny over pain management protocols and patient safety measures. The administration of opioid medications requires careful monitoring due to the risk of respiratory depression and other serious complications that can lead to brain injury from oxygen deprivation.
The case highlights the critical importance of expert witness testimony in medical malpractice litigation. Plaintiffs typically must establish through expert testimony that the defendant healthcare provider deviated from the accepted standard of care and that this deviation caused the plaintiff's injuries. The exclusion of expert testimony can be fatal to a malpractice claim, making appellate review of such decisions particularly important.
The South Dakota Supreme Court's decision in *Walton v. Huron Regional Medical Center* will likely provide guidance for future cases involving the admissibility of expert testimony in medical malpractice actions. The ruling may clarify how state courts should apply reliability standards when evaluating causation experts in complex medical cases.
The mixed nature of the court's decision suggests that the case may continue in the lower court for further proceedings, depending on which specific aspects of the circuit court's ruling were reversed. Both parties may need to reassess their litigation strategies based on the high court's guidance on expert witness standards and other legal issues addressed in the opinion.