James Kujawski, special administrator of the estate of Angeline Ciesielczyk, appeals from a judgment dismissing the complaint against Arbor View Health Care Center, a nursing home, and its owners and insurer. Ciesielczyk was injured when she fell out of her wheelchair while a resident at Arbor View. Kujawski claimed that the nursing home was *180negligent in failing to provide some sort of safety device to prevent decedent from falling out of the wheelchair. The dispositive issue is whether expert testimony was necessary to establish the standard of care the nursing home and its employes owed to decedent. We hold that expert testimony was necessary, and because Kujawski failed to provide it, the trial court properly dismissed the complaint.
Kujawski presented evidence that decedent was old and suffered from various physical disabilities. She could not walk on her own and needed help to move from her bed to her wheelchair. She was too big for her wheelchair. She fell out of her wheelchair on four previous occasions. On one such occasion she was alone and attempted to get out of her wheelchair. Arbor View had seatbelts to secure patients in wheelchairs. The employes assigned to push decedent in her wheelchair were never trained when and how to use a seatbelt on a resident.
November 11,1982, an Arbor View aide pushed decedent in her wheelchair toward a bingo table. Decedent's lap robe fell to the floor, she attempted to retrieve it, and the aide got it for her. The aide continued pushing the chair toward the table. When decedent was about 2-1/2 feet from the table, she moved as if to pull herself up to the table but leaned over and fell out of the chair. Her head was lacerated and her right thigh fractured. The leg did not heal and was amputated. Her condition deteriorated and she died the following summer.
The trial court granted Arbor View's motion to dismiss at the close of Kujawski's case because no expert testimony established the standard of care owed by Arbor View to decedent. Kujawski argues that it is in*181conceivable that jurors would need an expert to tell them how a nursing home should handle a resident such as decedent.
If necessary expert testimony is lacking, the case may be dismissed for insufficient proof. Cramer v. Theda Clark Memorial Hospital, 45 Wis. 2d 147, 152, 172 N.W.2d 427, 429 (1969). We consider the necessity for expert testimony without deference to the trial court's opinion. Olfe v. Gordon, 93 Wis. 2d 173, 179-85, 286 N.W.2d 573, 576-78 (1980); Cramer, 45 Wis. 2d at 153-54, 172 N.W.2d at 430-31. Expert testimony is not necessary unless the subject matter involved is outside the realm of the ordinary experience of mankind, and requires special learning, study or experience. Cramer, 45 Wis. 2d at 150, 172 N.W.2d at 428-29. The Cramer court concluded that expert testimony is not required to determine whether a hospital patient should be in or out of restraints. Id. at 154, 172 N.W.2d at 431.
Since Cramer was decided, whether a physical restraint should be imposed upon a resident in a nursing home has been removed from the conjecture of lay persons by regulations of the Department of Health and Social Services adopted in 1977. See Wis. Adm. Code sec. H 32.055(l)(k), Cr. Register, February 1977, No. 254, eff. 3-1-77. Wisconsin Adm. Code sec. HSS 132.31(l)(k) provides that a nursing home resident has the right to be free of physical restraints "except as authorized in writing by a physician for a specified and limited period of time and documented in the resident's *182medical record."1 A medical decision is therefore necessary before a restraint may be imposed on a nursing home resident.
That conclusion is buttressed by Wis. Adm. Code sec. HSS 132.60(6), adopted in 1974. See Wis. Adm. Code sec. H 32.10(4), Cr. Register, November 1974, No. 227, eff. 12-2-74. Section HSS 132.60(6) defines physical restraints and allows such restraints only on the order of a physician:
(6) Physical and chemical restraints.
(a) Definitions. As used in this subsection, the following definitions apply:
1. "Physical restraint" means any article, device, or garment which is used primarily to modify resident behavior by interfering with the free movement of the resident, and which the resident is unable to remove easily, or confinement in a locked room. Mechanical supports shall not be considered physical restraints.
Residents' Rights. Every resident shall, except as provided in sub. (4), have the right to:
(k) Abuse and restraints. Be free from mental and physical abuse, and be free from chemical and physical restraints except as authorized in writing by a physician for a specified and limited period of time and documented in the resident’s medical record. Physical restraints may be used in an emergency when necessary to protect the resident from injury to himself or herself or others or to property. However, authorization for continuing use of the physical restraints shall be secured from a physician within 12 hours. Any use of physical restraints shall be noted in the resident's medical records. "Physical restraint" includes, but is not limited to, any article, device, or garment which interferes with the free movement of the resident and which the resident is unable to remove easily, and confinement in a locked room.
*1832. "Mechanical support" means any article, device, or garment which is used only to achieve the proper position or balance of the resident, which may include but is not limited to a geri chair, posey belt, jacket, or a bedside rail.
(b) Orders required. Physical or chemical restraints shall be applied or administered only on the written order of a physician which shall indicate the resident's name, the reason for restraint, and the period during which the restraint is to be applied.
Plaintiff contends that a seatbelt or similar wheelchair safety device is a mechanical support, as defined in Wis. Adm. Code sec. HSS 132.60(6)(a)2, and is therefore excluded from the requirement of a physician's order. That contention does not ring true in view of his own characterization of decedent as old, senile, excitable and unable to look after herself, and his reliance upon at least one other instance in which she apparently attempted to stand up alone and fell from her wheelchair.
Plaintiff introduced two seatbelts in evidence which were easily undone. He points out that if a resident can "easily remove" a device, it is not, as defined in Wis. Adm. Code sec. HSS 132.60(6)(a)l, a restraint, and if it is not a restraint, no doctor's order or medical judgment is necessary.
Given decedent's physical and mental condition, however, whether she required a restraining device, or whether an easily removable safety device would have sufficed, is itself a medical decision.
We conclude expert testimony was required on the seatbelt issue. Because plaintiff presented no such tes*184timony, the trial court properly dismissed the complaint.
By the Court. — Judgment affirmed.
Wisconsin Adm. Code sec. HSS 132.31(1) provides in material part: