Traditionally there have not been informed consent cases predicated on the physician failing to warn the patient about personal risks the physician might expose the patient to. These could include infection with hepatitis b, Parkinson’s disease in a surgeon, or other mental or physical impairments that interfere with the physician’s abilities. The presumption was that a physician who had a condition that might injure a patient should refrain from putting patients at risk, and if the physician did injure the patient, it would be malpractice, rather than informed consent. (There are few reported cases, probably because if the disability and its adverse impact on the patient could be proven, the case would be settled.)