a federal court ruled

that the doctrine of informed consent required a

physician to furnish a patient contemplating

pregnancy with information concerning the

teratogenicity of the phenytoin she was taking. The

physician had a duty to provide information

reasonably available in the medical literature, but

failed to do so. Even though the physician was not

aware of the potential effects of phenytoin, studies

were reported in the medical literature. This case

represents the only case in which a lack of a

literature search resulted in liability.