Does the court have discretion to require expert testimony on the standard of care in an informed consent case?

Mathews challenges the trial court's discretion to require expert testimony on the standard of care in an informed consent case. But the categories of information that need to be disclosed to patients are not always free from ambiguity. "[S]ituations will sometimes arise in which the trier of fact is unable to decide the ultimate issue of the adequacy of a particular disclosure without an understanding of the standard of practice within the relevant medical community." (Arato v. Avedon, supra, 5 Cal.4th at p. 1191.) In those cases, "the testimony of medical experts qualified to offer an opinion regarding what, if any, disclosures--in addition to those relating to the risk of death or serious injury and significant potential complications posed by consenting to or declining a proposed treatment--would be made to the patient by a skilled practitioner in the relevant community under the circumstances, is relevant and admissible." (Ibid.) Mathews has not shown the trial court abused its discretion by requiring such evidence.