Washburn v. Bruffett,
N. CA 01-00553 (Ark. App. Feb. 27, 2002)

A patient sued two resident physicians, claiming a lack of informed consent after she consented to a surgical procedure to be performed by one surgeon, but underwent an unsuccessful procedure by the two residents. The Court of Appeals of Arkansas ruled that that presented a triable question of fact as to whether "reasonable persons might conclude that it was more probable than not" that her injury was caused by the resident physicians.