What is the standard of disclosure required for informed consent in medical malpractice cases?

"[T]he duty to disclose risks of death, serious injury, or significant complications is not defined by the custom or practice of the medical community. Instead, such a potential peril must be divulged if it would be material to the patient's decision, regardless of the custom in the profession." (Spann v. Irwin Memorial Blood Centers (1995) 34 Cal.App.4th 644, 655.) These disclosures are referred to as the minimal requisite disclosures for informed consent. "In addition to these `minimal' disclosures, the physician must also reveal to the patient `such additional information as a skilled practitioner of good standing would provide under similar circumstances.'" (Id. at p. 657.) "[A] physician is liable only where the failure to disclose causes the injury. [Citations.] `There must be a causal relationship between the physician's failure to inform and injury to the plaintiff. Such causal connection arises only if it is established that had revelation been made consent to treatment would not have been given.' [Citation.] Moreover, causation must be established by an objective test: that is, the plaintiff must show that reasonable `prudent person[s]' in the patient's position would decline the procedure if they knew all significant perils." (Ibid.) A bald declaration of the patient that the patient would have sought other treatment had the patient been accurately informed of the risks is not sufficient to defeat summary judgment. (Id. at p. 659.)