Question: Which of these cases established the idea of "informed consent" to medical procedures: Canterbury v. Spence or Obergefell v. Hodges?
Context: Madrigal v. Quilligan was a federal class action lawsuit from Los Angeles County, California involving sterilization of Latina women that occurred either without informed consent, or through coercion.  Although the judge ruled in favor of the doctors, the case led to better informed consent for patients, especially those who are not native English speakers. Informed consent is a process for getting permission before conducting a healthcare intervention on a person.  A health care provider may ask a patient to consent to receive therapy before providing it, or a clinical researcher may ask a research participant before enrolling that person into a clinical trial.  Informed consent is collected according to guidelines from the fields of medical ethics and research ethics. The terms genital modification and genital mutilation can refer to permanent or temporary changes to human sex organs.  Some forms of genital alteration are performed on an adult at his or her own behest, with their informed consent.  Other forms are performed on people who do not give informed consent, including infants or children.  Any of these procedures may be considered modifications or mutilations by different groups of people. Canterbury v. Spence (464 F.2d.  772, 782 D.C. Cir.  1972) was a landmark federal case decided by the United States Court of Appeals for the District of Columbia Circuit that significantly reshaped malpractice law in the United States.  It established the idea of "informed consent" to medical procedures. Prior to the landmark ruling "United States v. Windsor", the constitutionality of banning same-sex marriage was upheld by the Eighth Circuit in "Citizens for Equal Protection v. Bruning".  After the "Windsor" ruling, many same-sex marriage bans were struck down by lower courts.  The Tenth, Fourth, Seventh, and Ninth circuits all ruled that same-sex marriage bans were unconstitutional.  The cases that made it to these circuit courts originated in district courts which for the most part also struck down same-sex marriage bans.  When a circuit court struck down a state's same-sex marriage ban, it did not directly strike down same-sex marriage bans in other states within the circuit.  However, it paved the way for same-sex marriage bans to be struck down in the entire circuit due to the precedent it set for district courts within the circuit to follow.  In some states, same-sex marriage was already legal before a federal circuit court ruled on the matter.  The Sixth Circuit ruled that same-sex marriage bans were not unconstitutional and reversed the district court rulings that struck down same-sex marriage bans.  Since this was the only circuit court to rule this way post-"Windsor", this created a circuit split which ultimately led to the Supreme Court of the United States deciding to resolve the issue once and for all.  They ruled that same-sex marriage bans violate the constitution in the landmark ruling "Obergefell v. Hodges" which was the consolidated case that covered each state in the Sixth Circuit.  Some circuit courts have not ruled on the constitutionality of same-sex marriage bans at all.  Many circuit courts had pending same-sex marriage cases, but decided to hold off on litigation until the Supreme Court ruled on the matter. Bellotti v. Baird, 428 U.S. 132 (1976) , was a United States Supreme Court case in which the Court upheld a Massachusetts law requiring parental consent to a minor's abortion, which provided that "if one or both of the [minor]'s parents refuse ... consent, consent may be obtained by order of a judge ... for good cause shown."  The decision was unanimous, and the opinion of the Court was written by Justice Blackmun.  The law in question "permits a minor capable of giving informed consent to obtain a court order allowing abortion without parental consultation, and further permits even a minor incapable of giving informed consent to obtain an abortion order without parental consultation where it is shown that abortion would be in her best interests." In re A.C. was a 1987 D.C. Circuit reproductive rights case.  It was the first appellate court case decided against forced Caesarean sections, although the decision was issued after the fatal procedure was performed.  Physicians performed a Caesarean section upon patient Angela Carder (née Stoner) without informed consent in an unsuccessful attempt to save the life of her fetus.  The case stands as a landmark in United States case law establishing the rights of informed consent and bodily integrity for pregnant women. On April 28, 2015, the Supreme Court of the United States heard oral arguments for "Obergefell v. Hodges" (Ohio), which was consolidated with three other same-sex marriage cases from the other states in the Sixth Circuit: "Tanco v. Haslam" (Tennessee), "DeBoer v. Snyder" (Michigan), "Bourke v. Beshear" (Kentucky).  On June 26, 2015 the Supreme Court reversed the Sixth Circuit's decision, paving the way for same-sex marriage to become legal in those states, and setting a precedent for the entire nation.  All four states complied with the ruling the same day it was issued before the mandate was actually issued.  Every state in the circuit had a district court ruling against their states' ban, but they were eventually stayed pending appeal.  The Sixth Circuit consists of Kentucky, Michigan, Ohio, and Tennessee.  On August 6, 2014, the Sixth Circuit heard oral arguments for same-sex marriage cases from each state within the circuit.  On November 6, 2014, the Sixth Circuit in a split 2-1 decision, upheld the states' same-sex marriage bans, reversing the district courts' rulings that struck them down.  The Sixth Circuit was the first and only circuit court since the landmark ruling "United States v. Windsor" to uphold the constitutionality of states' same-sex marriage bans which caused a circuit split. African countries have been sites for clinical trials by large pharmaceutical companies, raising human rights concerns.  Incidents of unethical experimentation, clinical trials lacking properly informed consent, and forced medical procedures have been claimed and prosecuted. Obergefell v. Hodges, 576 U.S. ___ (2015) ( ), is a landmark civil rights case in which the United States Supreme Court ruled that the fundamental right to marry is guaranteed to same-sex couples by both the Due Process Clause and the Equal Protection Clause of the Fourteenth Amendment to the United States Constitution in a 5–4 decision.
Answer: Canterbury v. Spence