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Minnie Lee and Mary Alice Relf (who were 12 and 14 years old in 1973, respectively) are two African-American sisters who were involuntarily sterilized by tubal ligation by a federally funded family planning clinic in Montgomery, Alabama in 1973. News coverage of a class-action lawsuit filed by the Southern Poverty Law Center brought U.S. government-funded sterilization abuse to the national spotlight.
Mary Alice and Minnie Lee are the youngest of six children born to Lonnie and Minnie Relf. [1] The Relf family experienced poverty while living in Montgomery, Alabama. Lonnie Relf, having been injured in a car accident, was unable to work and neither he nor his wife, Minnie, were able to read or write. [2] The family received support from the Montgomery, Alabama, Community Action Committee which, in 1971, relocated the family to live in public housing. [3]
At the time of the case, in 1973, women of color were a major target of coerced sterilization in the United States. In North Carolina, 65% of sterilization operations were performed on African American women, although only 25% of its female population was black. [4] Mary Alice and Minnie were not the only African American minors who were forcibly sterilized during the 1970s. The same family planning clinic used by the Relfs sterilized a total of 11 female minors, 10 of whom were black. [5] This investigation led to a further discovery of many more involuntary procedures on minors across the United States. From a total of 3,260 government-funded birth control clinics, another 80 minors were found to have been coercively sterilized. [5] One case involved Deborah Blackmon, an African American woman from North Carolina who was involuntarily sterilized at 14 years old via a total abdominal hysterectomy in January 1972 due to the court judging her to be "severely mentally retarded". [6] [7] Due to her undergoing the procedure under county authority, as opposed to state, Blackmon was never compensated for the procedure. [8] A majority of these girls came from poor families. The Relf case helped expose thousands of sterilization procedures that did not involve consent, the majority of which involved African American women. [9]
Eugenicists sought to improve society by discouraging reproduction in populations deemed "inferior". Those who were deemed inferior included people who were mentally disabled. [4] A 1937 U.S. policy titled "Law 116" stated that, in the U.S. territory of Puerto Rico, those who were "feeble-minded" and "diseased" could be permanently sterilized. Lawmakers believed that these individuals were inept in making decisions about their reproductive abilities. They also did not want the mentally ill to pass on their genetic traits to their offspring. The United States used this reasoning as justification for the sterilizations previously performed as well as for future sterilization procedures. [10] Law 116 was repealed in 1960.
The Relf sisters were involuntarily sterilized in 1973. In 1971, when Montgomery Community Action (MCA) moved the Relf family into public housing, the family planning service of MCA "began the unsolicited administration of experimental birth control injections", containing Depo-Provera, on Katie Relf, Minnie Lee and Mary Alice's older sister. [3] In March 1973, Katie, a minor, had been taken to the family planning clinic, where she had an intrauterine device, or IUD, insertion procedure. Neither of Katie's parents was asked to give permission for Katie to receive this form of birth control, and Katie "submitted to the directions of the clinic staff that she accept implantation of the device." [3]
In June 1973, two social workers from Montgomery Community visited the Relf residence with concerns that young boys were "hanging around" Minnie Lee and Mary Alice, who were both mentally disabled. [11] [12] Lonnie was not home. [13] The MCA workers told Minnie that her daughters were going to receive some "shots." [3] The three were transported to a hospital, where Minnie, who could neither read nor write, signed a consent form with "X." [3] [13] She believed that Mary Alice and Minnie Lee were going to be given hormonal contraception injections, as they had received previously. [5] Later that day, Katie Relf, 17 years old at the time, was visited at her family home by a "nurse" seeking to have her be sterilized. Being a minor and home alone, she refused, locking herself in her room. [3]
The following day, Lonnie went to visit his daughters at the hospital. When he arrived, he was advised that visiting hours were over and he could not see his daughters that day. [5] Following three days in the hospital, the girls were sent home. Lonnie later noticed surgical scars on both of his youngest daughters' bodies. He asked his social worker what had actually happened. On realizing that their daughters had been sterilized without their consent, the Relfs filed a class-action lawsuit in the United States District Court for the District of Columbia with the help of the Southern Poverty Law Center. [1] Katie Relf would also sue with her sisters in the court case of Relf v. Weinberger, which resulted in a prohibition against the use of federal funds for involuntary sterilization. [11] The defendants in the case, Caspar Weinberger, secretary of the Department of Health, Education and Welfare (HEW) and then-director of the Office of Economic Opportunity (OEO) Alvin J. Arnett were accused in the complaint of having "used federal funds and the powers devolved upon them to bring about the use of birth control measures, including sterilization, on the plaintiffs (in the case of OEO) and the class they represent (in the case of OEO and HEW)[...]The defendants Caspar Weinberger and Arnett as well as their predecessors in office were found to have acted to deny plaintiffs and their class status the right to procreate, which is a constitutionally protected right, by failing to establish any guidelines for birth control programs conducted with federal funds, under federal auspices or by failing to distribute such guidelines once formulated." [3]
Sterilization is any of a number of medical methods of permanent birth control that intentionally leaves a person unable to reproduce. Sterilization methods include both surgical and non-surgical options for both males and females. Sterilization procedures are intended to be permanent; reversal is generally difficult.
Caspar Willard Weinberger was an American politician and businessman. As a Republican, he served in a variety of state and federal positions for three decades, most notably as Secretary of Defense under President Ronald Reagan from January 1981 to November 1987. He was indicted on charges of lying to Congress and obstructing government investigations as part of the Iran–Contra investigation, but was pardoned by President George H. W. Bush before facing trial.
The Eugenics Board of North Carolina (EBNC) was a State Board of the U.S. state of North Carolina formed in July 1933 by the North Carolina State Legislature by the passage of House Bill 1013, entitled "An Act to Amend Chapter 34 of the Public Laws of 1929 of North Carolina Relating to the Sterilization of Persons Mentally Defective". This Bill formally repealed a 1929 law, which had been ruled as unconstitutional by the North Carolina Supreme Court earlier in the year.
Buck v. Bell, 274 U.S. 200 (1927), is a decision of the United States Supreme Court, written by Justice Oliver Wendell Holmes Jr., in which the Court ruled that a state statute permitting compulsory sterilization of the unfit, including the intellectually disabled, "for the protection and health of the state" did not violate the Due Process Clause of the Fourteenth Amendment to the United States Constitution. Despite the changing attitudes in the coming decades regarding sterilization, the Supreme Court has never expressly overturned Buck v. Bell. It is widely believed to have been weakened by Skinner v. Oklahoma, 316 U.S. 535 (1942), which involved compulsory sterilization of male habitual criminals. Legal scholar and Holmes biographer G. Edward White, in fact, wrote, "the Supreme Court has distinguished the case [Buck v. Bell] out of existence". In addition, federal statutes, including the Rehabilitation Act of 1973 and the Americans with Disabilities Act of 1990, provide protections for people with disabilities, defined as both physical and mental impairments.
Compulsory sterilization, also known as forced or coerced sterilization, refers to any government-mandated program to involuntarily sterilize a specific group of people. Sterilization removes a person's capacity to reproduce, and is usually done by surgical or chemical means.
Carrie Elizabeth Buck was the plaintiff in the United States Supreme Court case Buck v. Bell, after having been ordered to undergo compulsory sterilization for purportedly being "feeble-minded" by her foster parents after their nephew raped and impregnated her. She had given birth to an illegitimate child without the means to support it. The surgery, carried out while Buck was an inmate of the Virginia State Colony for Epileptics and Feebleminded, took place under the authority of the Sterilization Act of 1924, part of the Commonwealth of Virginia's eugenics program.
In 1924, the Virginia General Assembly enacted the Racial Integrity Act. The act reinforced racial segregation by prohibiting interracial marriage and classifying as "white" a person "who has no trace whatsoever of any blood other than Caucasian". The act, an outgrowth of eugenicist and scientific racist propaganda, was pushed by Walter Plecker, a white supremacist and eugenicist who held the post of registrar of the Virginia Bureau of Vital Statistics.
Eugenics has influenced political, public health and social movements in Japan since the late 19th and early 20th century. Originally brought to Japan through the United States, through Mendelian inheritance by way of German influences, and French Lamarckian eugenic written studies of the late 19th and early 20th centuries. Eugenics as a science was hotly debated at the beginning of the 20th, in Jinsei-Der Mensch, the first eugenics journal in the Empire. As the Japanese sought to close ranks with the West, this practice was adopted wholesale, along with colonialism and its justifications.
In the United States and its territories, Community Action Agencies (CAA) are local private and public non-profit organizations that carry out the Community Action Program (CAP), which was founded by the 1964 Economic Opportunity Act to fight poverty by empowering the poor as part of the War on Poverty.
Compulsory sterilization in Canada has a documented history in the provinces of Alberta, Saskatchewan, and British Columbia. It is still ongoing as in 2017, sixty Indigenous women in Saskatchewan sued the provincial government, claiming they had been forced to accept sterilization before seeing their newborn babies. In June 2021, the Standing Committee on Human Rights in Canada found that compulsory sterilization is ongoing in Canada and its extent has been underestimated.
Eugenics, the set of beliefs and practices which aims at improving the genetic quality of the human population, played a significant role in the history and culture of the United States from the late 19th century into the mid-20th century. The cause became increasingly promoted by intellectuals of the Progressive Era.
Helen Rodríguez Trías was an American pediatrician, educator and women's rights activist. She was the first Latina president of the American Public Health Association (APHA), a founding member of the Women's Caucus of the APHA, and a recipient of the Presidential Citizens Medal. She is credited with helping to expand the range of public health services for women and children in minority and low-income populations around the world.
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.
Eugenics in California is a notable part of eugenics in the United States. As an early leading force in the field of eugenics, California became the third state in the United States to enact a sterilization law. By 1921, California had accounted for 80% of sterilizations nationwide. This continued until the Civil Rights Movement, when widespread critiques against society's "total institutions" dismantled popular acceptance for the state's forced sterilizations. There were an estimated 20,000 forced sterilizations in California between 1909 and 1979; however, that number may be an underestimation. In 2021, California enacted a reparations program to compensate the hundreds of still living victims from its eugenics program.
In the 1960s and 1970s, the Indian Health Service (IHS) and collaborating physicians sustained a practice of performing sterilizations on Native American women, in many cases without the free and informed consent of their patients. In some cases, women were misled into believing that the sterilization procedure was reversible. In other cases, sterilization was performed without the adequate understanding and consent of the patient, including cases in which the procedure was performed on minors as young as 11 years old. A compounding factor was the tendency of doctors to recommend sterilization to poor and minority women in cases where they would not have done so to a wealthier white patient. Other cases of abuse have been documented as well, including when health providers did not tell women they were going to be sterilized, or other forms of coercion including threatening to take away their welfare or healthcare.
African Americans', or Black Americans', access and use of birth control are central to many social, political, cultural and economic issues in the United States. Birth control policies in place during American slavery and the Jim Crow era highly influenced Black attitudes toward reproductive management methods. Other factors include African-American attitudes towards family, sex and reproduction, religious views, social support structures, black culture, and movements towards bodily autonomy.
Sterilization law is the area of law, within reproductive rights, that gives a person the right to choose or refuse reproductive sterilization and governs when the government may limit this fundamental right. Sterilization law includes federal and state constitutional law, statutory law, administrative law, and common law. This article primarily focuses on laws concerning compulsory sterilization that have not been repealed or abrogated and are still good laws, in whole or in part, in each jurisdiction.
Sterilization of Latinas has been practiced in the United States on women of different Latin American identities, including those from Puerto Rico and Mexico. There is a significant history of such sterilization practices being conducted involuntarily, in a coerced or forced manner, as well as in more subtle forms such as that of constrained choice. Forced sterilization was permissible by multiple states throughout various periods in the 20th century. Issues of state sterilization have persisted as recently as September 2020. Some sources credit the practice to theories of racial eugenics.
Eugenic feminism was a current of the women's suffrage movement which overlapped with [[eugenics]]. Originally coined by the Lebanese-British physician and vocal eugenicist Caleb Saleeby, the term has since been applied to summarize views held by prominent feminists of Great Britain and the United States. Some early suffragettes in Canada, especially a group known as The Famous Five, also pushed for various eugenic policies.
Compulsory sterilization of disabled people in the U.S. prison system was permitted in the United States from 1907 to the 1960s, during which approximately 60,000 people were sterilized, two-thirds of these people being women. During this time, compulsory sterilization was motivated by eugenics. There is a lengthy history when it comes to compulsory sterilization in the United States and legislation allowing compulsory sterilization pertaining to developmentally disabled people, the U.S. prison system, and marginalized communities.
