Q: Authorities ? - layperson knowledge of apparent fraud. Evidences exist. Expert testimony not required.

A: In California, expert testimony is generally required in medical malpractice cases to establish whether a defendant adhered to the prevailing standard of care. However, this requirement can be waived when the defendant's negligence is so apparent that a layperson can recognize it without the need for expert analysis. This principle is supported by the case of Flowers v. Torrance Memorial Hospital Medical Center (1994) 8 Cal.4th 992, 1001.

In cases of apparent hospice fraud, such as being referred to hospice care for a non-existent lethal illness, you might be dealing with a situation where the negligence is obvious to a layperson. For example, if you were fraudulently diagnosed with end-stage kidney disease, which is a severe and life-threatening condition that typically requires dialysis and has a poor prognosis, but medical evidence shows your kidneys are healthy, this discrepancy is likely clear enough that even those without medical training could recognize the fraud.

Other relevant authorities that might support your case include Fraud vitiates whatever it touches (Civ. Code, § 1572), which means that any fraudulent act can invalidate contracts and obligations. Additionally, the concept of **Res Ipsa Loquitur** (the thing speaks for itself) may apply, indicating that the nature of the harm is such that it implies negligence. In your situation, the evidence of a healthy kidney despite a diagnosis of terminal illness could strongly indicate fraudulent activity without needing an expert to explain the inconsistency.