1. 21. Many women accept cesareans they at first resist, under pressure from the doctor or even under threat of court action. Even if a clear rule were adopted prohibiting court intervention and coercion, it is difficult to delineate the boundaries between persuasion and force, and doctors would continue to have substantial leverage. In view of the influence doctors can exercise over the mother's decision, it may be no accident that many of the reported cases involve persons who follow unwaivable church doctrine.
2. 38. Bowes, Selgestad, , supra note 28, at 214.
3. 35. Ibid.
4. 73. Carey v. Population Services, International, 431 U.S. 678 (1977) (availability of contraception for minors age 16 and under)
5. Eisenstadt v. Baird, 405 U.S. 438 (1972) (availability of contraception for single persons).