California, United States of America
The following excerpt is from Arato v. Avedon, 11 Cal.Rptr.2d 169, 13 Cal.App.4th 1325 (Cal. App. 1992):
Also, expert testimony is not necessary where negligence is demonstrated by facts which can be evaluated by resort to common knowledge. (See Ales v. Ryan (1936) 8 Cal.2d 82, 100, 64 P.2d 409.)
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