New York

Canterbury v. Spence in New York Law

How Canterbury v. Spence applies in New York: state-specific rules, key cases, and bar exam notes for Torts.

State Approach

New York law incorporates the principles from Canterbury v. Spence by emphasizing the doctrine of informed consent in medical malpractice cases. Medical professionals are required to disclose information that a reasonable patient would consider significant in making treatment decisions.

State Rule
Informed consent requires healthcare providers in New York to disclose relevant risks and alternatives that a reasonable patient would consider material to their decision-making.
Significant State Cases

Tobin v. Gaitonde

The court held that failure to inform the patient of the risks associated with a procedure constituted a lack of informed consent, warranting damages.

Woods v. Hames

The court affirmed that a healthcare provider's inadequate disclosure of risks leads to liability if the patient suffers harm from a risk that was not disclosed.

Solomon v. Gould

The court indicated that informed consent does not only apply to surgical procedures but also extends to all forms of medical treatment decisions.

Comparison to Federal Law

New York's informed consent doctrine aligns with the federal standard under the common law; however, New York places a greater emphasis on what a reasonable patient would consider necessary information, rather than merely a subjective standard. This allows for a more patient-centered approach in evaluating disclosure obligations.

Bar Exam Note

Understanding informed consent and its application in tort law is critical for the New York bar exam, particularly under the topics of medical malpractice and negligence.

Practice Pointers
  • Always assess whether the physician met the reasonable patient standard in disclosing critical information.
  • Evaluate the materiality of the undisclosed risks related to the patient's condition and treatment choices.
  • Keep in mind that informed consent extends beyond surgeries to all medical decisions, including diagnostics and non-invasive treatments.

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