## Facts

- Ayesha Madyun, a pregnant patient at D.C. General Hospital, was in prolonged labor after ruptured membranes (approximately 48 hours before admission) and remained about seven centimeters dilated.
- The attending physician advised that a cesarean section was medically indicated because continued labor after prolonged rupture significantly increased the risk of fetal sepsis, potentially causing brain damage or death.
- The physician estimated the risk of fetal sepsis at 50–75% (given labor lasting about 60–70 hours) and estimated the risk of serious maternal harm from a cesarean at about 0.25%.
- Madyun refused consent, citing religious beliefs (as a Muslim), a desire for natural childbirth, and her view that the procedure was not medically necessary.
- At an emergency bedside hearing, Madyun testified that she understood the risks to the fetus but asserted the right to refuse surgery.
- Madyun’s husband supported her refusal and testified that it was her choice whether to undergo the procedure.
- The hospital filed an emergency petition seeking judicial authorization to perform the cesarean over Madyun’s objection.

## Issues

1. Whether a competent pregnant patient in labor may refuse a medically recommended cesarean section despite a serious and imminent risk of fetal harm or death.
2. Whether a court may authorize and effectively compel invasive surgery on a competent adult to protect the life or health of a viable fetus over the adult’s religious and bodily-integrity objections.
3. How a court should weigh comparative risks to the pregnant patient and the fetus in an asserted obstetric emergency.

## Decision

- The Superior Court granted the hospital’s emergency petition and authorized physicians to perform a cesarean section over Madyun’s objection.
- The court denied Madyun’s motion to stay the order, allowing the procedure to proceed immediately.
- The court’s ruling relied heavily on the comparative-risk evidence presented: high estimated fetal risk without surgery versus low estimated maternal risk with surgery.

## Legal Principles

- A trial court may, in an asserted obstetric emergency, authorize medical intervention over a competent pregnant patient’s refusal when presented with evidence of a high probability of serious fetal harm or death and comparatively low maternal risk from the procedure.
- In this proceeding, the court treated the state’s interest in preserving fetal life (and related institutional interests in preventing fetal harm) as sufficient to override a competent patient’s refusal grounded in bodily integrity and religious conviction.
- Comparative medical-risk testimony can be used to justify overriding refusal of treatment when the court characterizes the situation as time-sensitive and near-crisis for the fetus.

## Conclusion

The court authorized a cesarean section over the competent patient’s objection, concluding that the asserted emergency and the sharply higher estimated fetal risk justified overriding her refusal, despite her religious and autonomy-based claims.


In re Madyun, 114 Daily Wash. L. Rptr. 2233 (D.C. Super. Ct. 1986)