LAW.coLAW.co

Boyington v. Redner's Markets, Inc. v. Integrated Health Associates, Inc.

2026-08-26

Summary

Holding. The court affirmed that the resubmitted affidavit of merit complied with Delaware Code § 6853(a)(1) and (c), containing all statutorily required elements for a healthcare negligence claim against Integrated Health Associates.

Integrated Health Associates, LLC challenged whether the affidavit of merit filed by Redner's Markets satisfied Delaware's statutory requirements for healthcare negligence lawsuits. The court conducted an in camera review and initially rejected the affidavit for failing to comply with the statute. Redner's was given an opportunity to resubmit. Upon examining the revised affidavit and the expert's curriculum vitae, the court determined that all required elements were present: the affidavit was signed by a licensed medical expert with relevant board certification and clinical experience in the same medical field; it included a current curriculum vitae; and it contained the expert's opinions that the defendant breached the applicable standard of care and that this breach proximately caused the plaintiff's injuries, all stated with reasonable medical probability.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether affidavit of merit satisfied statutory signature and credentials requirements
  • Whether expert opinion adequately addressed standard of care breach
  • Whether expert opinion adequately addressed proximate causation
  • Whether expert qualifications met statutory experience requirements

Procedural posture

Integrated Health moved for in camera review of Redner's affidavit of merit under Delaware Code § 6853(d); the court initially rejected it, allowed resubmission, and then reviewed the amended affidavit.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion

majority opinion

IN THE SUPERIOR COURT OF THE STATE OF DELAWARE

CAROL BOYINGTON, )

)

Plaintiff, )

) C.A. No.: K24C-05-008 RLG

v. )

)

REDNER’S MARKETS, INC. )

)

Defendant/ )

Third-Party Plaintiff, )

)

INTEGRATED HEALTH )

ASSOCIATES, LLC, )

)

Third-Party Defendant. )

Submitted: July 28, 2026

Decided: August 26, 2026

ORDER

Upon Review of the Amended Affidavit of Merit – COMPLIANT

On April 8, 2025, Third-Party Defendant Integrated Health Associates, LLC,

(“Integrated Health”) filed a motion1 seeking the Court’s review of Third-Party

Plaintiff Redner’s Markets, Inc.’s (“Redner’s”) affidavit of merit, in camera, to

determine whether it complies with 18 Del. C. § 6853(a)(1) and (c).2 Specifically,

1

D.I. 52.

2

See 18 Del. C. § 6853(d) (“Upon motion by the defendant[,] the Court shall determine in camera if the affidavit of merit complies with paragraph (a)(1) and subsection (c) of this section.”).

1

Integrated Health requested the Court review the affidavit of merit to ensure: (1) it

is signed by an expert witness; (2) it is accompanied by that witness’s curriculum

vitae; (3) it states all opinions with a reasonable degree of medical probability; (4)

the expert witness gives an opinion that there has been healthcare medical negligence

by Integrated Health; (5) the expert gives an opinion that each breach by Integrated

Health was a proximate cause of the injuries alleged in the Complaint; and (6) the

expert’s curriculum vitae establishes that the expert has been engaged in the

treatment of patients, or in the academic side of skilled nursing, for the three years

preceding the negligent act.3 The Court conducted the requested in camera review,

and rejected the affidavit of merit for failure to comply with 18 Del. C. § 6853(a).4

The Court afforded Redner’s an opportunity to resubmit the affidavit of merit to

ensure its compliance with all the statutory requirements.5

18 Del. C. § 6853(a) requires all healthcare negligence lawsuits be

accompanied by “an affidavit of merit as to each defendant signed by an expert

witness … and accompanied by a current curriculum vitae of the witness, stating

that there are reasonable grounds to believe that there has been healthcare medical

negligence committed by each defendant.” Under 18 Del. C. § 6853(c), the affidavit

3

D.I. 52 at 1-2.

4

Boyington v. Redner’s Markets, Inc., 2026 WL 2065748, at *2 (Del. Super. Jul. 15, 2026). 5

Id.

2

of merit must “set forth the expert’s opinion that there are reasonable grounds to

believe that the applicable standard of care was breached by the named defendant or

defendants and that the breach was a proximate cause of injury or injuries claimed

in the complaint.” The requirements of 18 Del. C. § 6853 “are purposefully

minimal.”6

Having reviewed the resubmitted affidavit of merit and the expert witness’s

curriculum vitae, the Court finds:

1. The expert signed the affidavit.

2. The expert attached a current curriculum vitae.

3. The expert is currently licensed to practice medicine.

4. The expert has been treating patients in the same or similar field of

medicine as Integrated Health. Specifically, the affidavit and

accompanying curriculum vitae note the expert’s board certification in

physical medicine and rehabilitation and his experience in private

practice providing treatment to patients requiring physical medicine

and rehabilitation.

5. The expert opines there are reasonable grounds to believe Integrated

Health breached the standard of care in its care of Plaintiff Carol

6

Dishmon v. Fucci, 32 A.3d 338, 342 (Del. 2011) (citing Green v. Weinger, 766 A.2d 492, 495-96 (Del. 2001)).

3

Boyington. The expert further opines that breach was the proximate

cause of Ms. Boyington’s injuries.

The affidavit of merit contains the information required by 18 Del. C. §§ 6853(a)(1)

and (c) as to the allegations involving Integrated Health. Therefore, the affidavit of

merit is COMPLIANT.

IT IS SO ORDERED.

4