What is the effect of the modified objective approach to the issue of causation in medical malpractice cases?

92. The modified objective approach to the issue of causation, as described in Reibl v. Hughes, deprives the plaintiff's sworn testimony on that issue of any weight. I understand that the rule resulted from a concern that plaintiffs in such cases could always be expected to give evidence to the effect that the very treatment excluded from consideration by reason of the failure to disclose would necessarily have been the treatment of choice had full disclosure been made. But the difficulty, which the trier of fact assessing the credibility of such evidence faces, seems to me to be no greater than that which arises in any other case where the task is to decide what would have happened if that which did take place had not occurred, and that which did not take place had. With respect, the desire to shield the physician from "the patient's hindsight and bitterness", emotions which could hardly be said to be unique to plaintiffs in medical malpractice actions, does not seem sufficient justification for a rule that deprives credible plaintiffs of the right to be believed by the trier of fact in such cases.