On January 19, 2012 the Arkansas Supreme Court ruled in Broussard v. St. Edward Mercy Health System, Inc., 2012 Ark. 14, 2012 WL 149761 (2012) that a statute requiring experts in medical malpractice cases to be of the same specialty as the defendant was unconstitutional. Ark. Code section 16-114-206(a) provided that plaintiff must prove a standard of care violation by an expert “medical care provider of the same specialty as the defendant.” Plaintiff/Appellant argued that the statute created a procedural rule, and that only the supreme court – not the legislature – can create procedural rules. The supreme court agreed, holding the statute violated the separation of powers doctrine and was void.