Despite recent declines, the teen birth rate in the United States remains markedly higher than in other developed countries. Infants born to teen mothers are more likely to be preterm than those born to adult mothers and thus more likely to end up in the newborn intensive care unit (NICU). Critically ill newborns are not infrequently born to teen mothers, including those in early adolescence. The focus of this chapter is the mechanism of decision-making on behalf of those newborns and the role of the early adolescent mother as surrogate decision-maker. It is argued that the current standard in many US hospitals, and likely elsewhere, is suboptimal and inadequately addresses the rights and needs of both mother and newborn.