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.