Mitchell, L. v. E. Shikora, D.O., Aplts.

I concur in the result reached by the learned Majority. I write separately to highlight four areas of concern.

I

As the Majority notes, evidence of consent is not relevant to the issue of negligence, inasmuch as a patient's consent does not make a physician's negligence more or less probable. Maj. Op. at 317-18. On the other hand, evidence of risks and complications "may aid the jury in determining both the standard of care and whether the physician's conduct deviated from the standard of care." Id. at 318. Importantly, the Majority recognizes that *324these are "two discrete categories of…