Possibly, but not necessarily. A doctor has a duty to tell a patient about any significant risks involved in a procedure, but they do not need to tell a patient about every imaginable risk. Failing to tell a patient about a significant risk may result in liability under the theory that they did not get informed consent. (This rule does not apply in emergencies, since a doctor does not have time to get informed consent.) A patient bringing a claim based on a lack of informed consent will need to show that a competent doctor would have disclosed the risk, or that a reasonable patient would have made a different decision if they had known about the risk.