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Puckett-Morrissette v. Durrani – Future Medical Expenses Reversed, 2026 Ohio 1444

The Ohio First District Court of Appeals affirmed in part, reversed in part, vacated in part, and remanded consolidated medical malpractice judgments involving three plaintiffs (Puckett-Morrissette, Reynolds, and Wyatt) against Dr. Abubakar Atiq Durrani and the Center for Advanced Spine Technologies, Inc. The court upheld the trial court's joinder of plaintiffs' claims and its admission of expert testimony under Evid.R. 601 and Evid.R. 702. The court reversed the trial court's award of future medical expenses for each plaintiff due to insufficient expert testimony establishing anticipated treatment course, likelihood of treatment, and projected costs. The court also reversed the denial of defendants' setoff request, holding that intentional tortfeasors are entitled to a setoff under R.C. 2307.28(A). The trial court's prejudgment interest award was affirmed. Defendants face recalculation of damages on remand.