Is Expert Testimony Required to Prove Tort Claim Asserting Lack of Informed Consent Prior to Surgery?

Robert N. White et al. v. Warren H. Leimbach, II, M.D., Case no. 2010-0988

10th District Court of Appeals (Franklin County)

ISSUE: When a patient sues a physician based on a claim that the doctor did not obtain the patient's "informed consent" to a surgical procedure because the doctor did not adequately warn the patient about the likelihood of post-surgical complications, is the plaintiff patient required to present expert witness testimony at trial to establish the alleged lack of informed consent?