What are the elements of a cause of action for professional negligence?

The elements of a cause of action for professional negligence are, of course, well defined. They are: (1) the duty of the professional to use such skill, prudence and diligence as other members of his profession commonly possess and exercise; (2) breach of that duty; (3) a proximate causal connection between the negligent conduct and the resulting injury; and (4) actual loss or damage stemming from the professional negligence (Ventura County Humane Society v. Holloway (1974) 40 Cal.App.3d 897, 902, 115 Cal.Rptr. 464). The cases dealing with medical malpractice consistently emphasize that a physician or surgeon is not liable for every untoward result which may occur in his medical practice. The law requires only that a physician or surgeon have the degree of learning and skill possessed by practitioners of the medical profession in the same locality and that he exercise ordinary[538 P.2d 718]

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