Mickens v. LaSala
Plaintiffs appealed an order granting summary judgment to defendants in a medical malpractice case. They alleged defendants failed to diagnose their son, Noah, with Down's syndrome in utero, seeking extraordinary expenses for his care. The Supreme Court, Kings County, granted summary judgment, finding plaintiffs had not incurred, and would not necessarily incur, such expenses due to government programs like the Individuals with Disabilities Education Act. The appellate court dismissed the appeal from the order but affirmed the judgment, holding that plaintiffs failed to provide proof of extraordinary financial obligations or expert testimony identifying unmet needs not covered by public expense, reinforcing that damages cannot be based on speculation.