Garcia v. Robinson.

Opinion of the Court by

POLLACK, J.

In Ray v. Kapiolani Medical Center, 125 Hawai'i 253, 259 P.3d 569 (2011), this court noted that Hawai'i Revised Statutes (HRS) § 671-3(b) supplies the standard for a physician’s duty to disclose information to the patient. Id. at 266, 259 P.3d at 582. Following Ray, in Ngo v. Queen’s Medical Center, 136 Hawai'i 54, 358 P.3d 26 (2015), we held that the prior formulation of the first element of the common law medical tort of negligent failure to obtain informed consent had changed from “the physician owed a duty to disclose the risk of one or more of the…