Attorneys are confronted by an ever increasing amount of litigation concerning miscarriage occasioned by physical and physic trauma. The proof and evaluation of the proximate cause of miscarriage is perplexing. The subject of miscarriage is not a matter of common knowledge, hence the members of the jury are not competent to determine, without expert testimony, whether trauma is the proximate cause of the miscarriage. To add to the burden of proof, the courts have not always adhered to correct medical terminology. But it is particularly important that the correct terms be employed, and expert testimony must be given by competent authority.
Beryl W. Stewart, Traumatic Miscarriage, 12 Clev.-Marshall L. Rev. 304 (1963)