Obstetric Experts on Gestational Diabetes Not Qualified To Testify As To Cause of Fetal Death

Obstetricians with experience in treating pregnant women with gestational diabetes could offer expert testimony regarding that condition, but could not testify that the mother’s gestational diabetes caused the death of a stillborn fetus.


The autopsy reported no anatomic cause of death. The witnesses offered as experts had experience consulting on and treating patients with gestational diabetes whose fetuses were stillborn. The physicians both testified they could form opinions as to the cause of death, even though a pathologist could not, by looking at a variety of factors. However, no evidence was presented regarding the scientific validity of these opinions.


The trial court found that neither obstetrician demonstrated a basis that their belief regarding the cause of death in the case constituted more than surmise or conjecture. Both experts were precluded from testifying as to the cause of death of the fetus. The appellate found that the trial court's exclusion of the testimony from the patient's expert on the basis that the patient failed to establish the expert's qualifications to offer expert testimony regarding the cause of death of the fetus was not an abuse of discretion.


See: Weaver v. McKnight, 134 Conn.App. 652 (Conn.App.  Apr 10, 2012).