When a plaintiff claims that a juvenile detention facility negligently hired, trained, and supervised personnel resulting in a death, expert testimony is required.

The US district court, in the case of Grimes v. District of Columbia, 923 F. Supp. 2d 196 – Dist. Court, Dist. of Columbia 2013 stated:

Expert testimony on the applicable standard is required “if the subject in question is so distinctly related to some science, profession or occupation as to be beyond the ken of the average layperson.” District of Columbia v. Arnold & Porter, 756 A.2d 427, 433 (D.C.2000) (citations omitted). Here, plaintiffs negligence claim relates to the hiring, training, and supervision of personnel in a juvenile detention facility. Plaintiff cannot possibly establish the applicable standard of care without expert testimony because the average layperson does not possess the technical knowledge needed to judge staffing and security needs at a juvenile detention facility. Defendant is therefore entitled to summary judgment as a matter of law as plaintiff has failed to designate an expert witness to define the standard of care.