Lashanda Spencer, as Administratrix of the Estate of Muriel Stewart, and Lashanda Spencer

Summary

The Court held that a plaintiff asserting lack of informed consent must prove proximate causation in addition to showing that the provider failed to disclose a material risk. Causation requires proof that a reasonable person in the plaintiff's circumstances would not have undergone the treatment, or would not have undergone the actual treatment that caused the injury, if properly informed. The Court therefore affirmed the judgment entered after the jury found that causation was not proven.