 In the wake of the Carder ruling, cases of forcing a manifestly competent pregnant woman to undergo an intervention over her objections have been rare. However, forced interventions are still sometimes performed on women who are vulnerable due to poverty, mental illness, immigration status, racism, etc. (Roth 2003, Roberts 1996). These vulnerable women, whose contact with the health care system is more likely to be fragmented, are more open to being assessed as incompetent when their expressed decision differs sharply from the judgment of medical professionals responsible for their care. Social marginalization can create the appearance of incompetence, and it can also genuinely hamper competence when it comes to negotiating physician-patient interactions.