I agree with the majority that there is no distinct cause of action for professional as opposed to ordinary negligence. I also agree with the majority inasmuch as the holding today does not alter the “common knowledge” exception to the usual rule that a plaintiff’s medical malpractice action must be supported by some expert evidence as to the proper community standard of care. (See Meier v. Ross General Hospital (1968) 69 Cal.2d 420, 429-431 [71 Cal.Rptr. 903, 445 P.2d 519].) Nor do I take issue with the majority’s deferral of the issue of whether or not the common knowledge exception applies in this case. (Maj. opn., ante, at p. 1001, fn. 5.)
I disagree, however, with the disposition of this case, because I believe the Court of Appeal was right in reversing the trial court’s grant of summary judgment, albeit not for all the right reasons. Summary judgment should only be granted “if all the papers submitted show that there is no triable issue as to any material fact and that the moving party is entitled to judgment as a matter of law.” (Code Civ. Proc., § 437c, subd. (c).) As we have stated, “[s]ummary judgment is a drastic measure that deprives the losing party of a trial on the merits. [Citation.] It should therefore be used with caution, so that it does not become a substitute for trial. [Citation.] The affidavits of the moving party should be strictly construed, and those of the opponent liberally construed. [Citation.] Any doubts as to the propriety of granting the *1003motion should be resolved in favor of the party opposing the motion.” (Molko v. Holy Spirit Assn. (1988) 46 Cal.3d 1092, 1107 [252 Cal.Rptr. 122, 762 P.2d 46].) A review of the record in this case reveals that, under the above standard, the trial court clearly erred in granting defendant hospital’s motion for summary judgment.
Plaintiff was in defendant’s care, allegedly with bladder pain, when she fell from a gurney and injured herself. The question is whether defendant hospital’s failure to put up both side rails on plaintiff’s gurney falls below the proper standard of care. It is evident that this question is not one of great technical complexity. As with other standard of care issues, a trier of fact must ultimately weigh the evidence to determine the proper standard, and whether the hospital departed from it.
One piece of evidence highly relevant to the foregoing determination is the hospital’s own policy statements on the appropriate medical procedures to be followed. Although such policy statements are not necessarily the definitive word on the community standard of care, they can be more reliable reflections of that standard than, for example, the declarations of expert witnesses: the former are forward-looking prescriptions of proper medical practice designed for the guidance of employees and staff, while the latter can be viewed as post hoc justifications of past behavior designed for use in litigation. Thus, even if this case does not fall within the “common knowledge” exception to the expert evidence rule, a hospital policy statement that contradicts the declarations of the hospital’s own expert witnesses as to the proper standard of care may raise a triable issue of fact that cannot be resolved on summary judgment.
The record in this case reveals that, in opposition to the motion for summary judgment, plaintiff produced a document authored by defendant hospital entitled “Orientation to the Emergency Department” for its new emergency employees. The document stated as follows: “Both side rails are to be up on a patient lying on a gurney; both side rails are up on a child lying on a gurney.” Defendant countered that the policy reflected in the above quoted passage applies only to children, but the plain language of the document belies that contention. Moreover, defendant contends that this “Orientation Packet” did not establish hospital policy; rather, a document called an “Emergency Policy and Procedures Manual” (Manual) was the hospital’s official word on when side rails should be put upright. That Manual sets forth the various conditions under which side rails are to be raised, and plaintiff in her situation arguably did not meet those conditions. But the precedence of the Manual over the Orientation Packet in this case is *1004by no means obvious. It is clear from the text of the Manual that the side rail policy mentioned in that document refers to side rails on beds, and that, unlike the above quoted passage from the Orientation Packet, gurneys are never mentioned.
Defendant also produced two declarations to the effect that the community standard of care at the time did not necessarily include putting up both side rails on gurneys. One declaration was given by a nurse who was an employee of the hospital, the other by a doctor whose relationship to the hospital was unclear. Both statements are somewhat conclusory. In light of the hospital’s own Orientation Packet, a reasonable trier of fact could legitimately view these declarations with skepticism.
Thus, in this case, there was at the very least a factual ambiguity as to the official hospital policy regarding side rails on gurneys. In fact, plaintiff’s case was arguably stronger than that of defendant, for the document relied on by plaintiff was the only one to explicitly mention gurneys rather than beds, and therefore was the document that came the closest to governing plaintiff’s situation. Although the trial court is required to strictly construe the moving party’s documents, and liberally construe those of the opponent, here it did precisely the reverse.
Because there was a question of material fact regarding care pursuant to hospital safety policy, and therefore regarding the proper standard of care in plaintiff’s situation, I would forego the needless exercise of remanding the case and uphold the Court of Appeal’s reversal of the summary judgment.