Shawn Liggett, as Special Administrator of the Estate of James Randal Liggett v. Timothy Young, Md

── Shawn Liggett, as Special Administrator of the Estate of James Randal Liggett v. Timothy Young, Md ── Court: Court of Appeals of Arkansas Date: April 22, 2026 Category: General Cite as 2026 Ark. App. 252 ARKANSAS COURT OF APPEALS DIVISION III No. CV-25-133 Opinion Delivered April 22, 2026 SHAWN LIGGETT, AS SPECIAL ADMINISTRATOR OF THE ESTATE OF APPEAL FROM THE SHARP JAMES RANDAL LIGGETT, DECEASED COUNTY CIRCUIT COURT APPELLANT [NO. 68CV-21-125] V. HONORABLE ROB RATTON, JUDGE TIMOTHY YOUNG, MD AFFIRMED APPELLEE MIKE MURPHY, Judge The appellant, Shawn Liggett, as special administrator of the estate of James Randal Liggett, deceased, appeals the decision of the Sharp County Circuit Court granting appellee Dr. Timothy Young’s motion for summary judgment. We affirm. In October 2021, the estate of Mr. Liggett sued Dr. Young, alleging medical malpractice and wrongful death. The complaint alleged that Mr. Liggett passed away due to complications from his type 1 diabetes that were avoidable but for Dr. Young’s negligence. Mr. Liggett was having trouble with his new insulin pump and high blood sugar and saw Dr. Young, his friend and doctor of over forty years, in clinic for his very high blood sugar on two occasions between the receipt of his pump and his hospitalization. During discovery, Dr. Isaacs was identified as the medical expert for the estate. He is an endocrinologist practicing in Atlanta, Georgia, and an adjunct instructor at Emory University School of Medicine. Dr. Isaacs practices in a suburb of Atlanta in an endocrinology clinic with four endocrinologists and approximately eleven rheumatologists. He holds privileges in the major hospital systems in Atlanta and has spent his entire career in the Atlanta area. He reviewed the medical records in this case. Dr. Isaacs did not know what types of medical facilities were available in Cherokee Village, Arkansas, nor did he know its population or major industries or the demographics of the people there. He has never been to Arkansas. Concerning the standard of care, he opined that while “there may be some limitations with access to care in smaller towns where certain things may not be available . . . in general, the standard of care for the management of diabetes is universal throughout the U.S.” He said that the standard of care in Atlanta is applicable to physicians in Cherokee Village, but he stated, “I think there could be some nuances related to access to care. And so without knowing the details of Cherokee Village, I would say that the general principles, separating out access issues, is the same.” He did not know what the “nuances” or “access issues” were as they relate to Cherokee Village other than his understanding that patients “had to travel to a different county to see an endocrinologist and things to that level.” The following exchange took place during his deposition: Q. Is the standard of care in Atlanta different from the standard of care in other communities across the nation? A. No. Q. Nationally, it’s the same? 2  A. I mean, again, there could be nuances related to access to care, but in general, the answer is it’s the same. .... Q. Does the standard of care, in your mind, take into account the differences in resources, customs, and habits of the community? A. It can. Q. But you just don’t know what those are specific to Cherokee Village? A. I don’t, but I also just the comment that I would make is that a lot of the standard of care is very easy to get nowadays in the U.S. as opposed to say in other countries. Access to