{"id":49970,"date":"2016-09-30T11:27:00","date_gmt":"2016-09-30T16:27:00","guid":{"rendered":"https:\/\/content.findlaw-admin.com\/ability-legal\/supreme\/legal-commentary\/a-judge-orders-a-woman-not-to-have-children-while-on-probation-did-he-violate-her-rights.html"},"modified":"2016-09-30T11:27:00","modified_gmt":"2016-09-30T16:27:00","slug":"a-judge-orders-a-woman-not-to-have-children-while-on-probation-did-he-violate-her-rights","status":"publish","type":"supreme","link":"https:\/\/supreme.findlaw.com\/legal-commentary\/a-judge-orders-a-woman-not-to-have-children-while-on-probation-did-he-violate-her-rights.html","title":{"rendered":"A Judge Orders a Woman Not to Have Children While On Probation: Did He Violate Her Rights?"},"content":{"rendered":"\n<div class=\"wp-container-core-columns-is-layout-9d6595d7  fl-block-columns fl-sectionWithSidebar fl-container fl-flex fl-flex-wrap fl-gap30\">\n    \n    <div class=\"fl-page-articles   fl-block-column fl-section-main fl-section-main-full-width\">\n        <div class=\"yui-g\" id=\"leftcol-module\">\n      <!-- Right Line of Links Section -->\n      <!-- BEGIN PICTURE INSERTION -->\n      <!-- BEGIN TITLE AND AUTHOR INSERTION -->\n      <table>\n        <tr>\n\n          <td width=\"100\" rowspan=\"3\" class=\"wiauthor\"><a href=\"\/legal-commentary\/sherry-colb-archive\"><img decoding=\"async\" src=\"https://supreme.findlaw.com/static/f/images\/writ\/sherry.colb.jpg\" border=\"0\"><\/a><\/td>\n          <td class=\"wititle\"><h1>A Judge Orders a Woman Not to Have Children While On Probation: Did He Violate Her Rights?<\/h1>\n<\/td>\n        <\/tr>\n        <tr>\n          <td class=\"wiauthor\"><a href=\"\/legal-commentary\/sherry-colb-archive\" class=\"graybold\"><h2>By SHERRY F. COLB <\/h2><br><\/a><\/td>\n        <\/tr>\n        <tr>\n          <td class=\"widate\">Wednesday, Nov. 26, 2008<\/td>\n        <\/tr>\n      <\/table>\n<span class=\"smalltext\">\n\n\n<p>In September, Texas judge Charlie Baird sentenced a woman to  ten years&#8217; probation for injury to a child by omission. The woman, twenty-year-old Felicia Salazar,  admitted that she had failed to protect her 19-month-old child from a brutal  beating by the child&#8217;s father, Robert Alvarado, and that she had failed to seek  medical care for the child&#8217;s injuries, which included broken bones. In addition to other, more ordinary probation  conditions (including 100 hours of community service and psychological  counseling), the judge ordered Salazar not to conceive and bear a child while  on probation. <\/p>\n<\/span>\n<p>In this column, I address the question whether such a probation  condition unconstitutionally infringes upon Salazar&#8217;s fundamental right to  procreate.<\/p>\n<p><strong>The Relevant Supreme  Court Precedents <\/strong><\/p>\n\n<span class=\"smalltext\">\n<!-- START TABLE FOR RELATED -->\n<div id=\"writthreetwenty\">\n<script language=\"JavaScript\" type=\"text\/javascript\">dart_call(\"300x250\", \"ptile=2\", 0); <\/script>\n\n<\/div>\n\n<p>The U.S. Supreme Court has yet to address a case that is  precisely on point for such a probation condition. Nonetheless, two lines of decisions are  relevant. One line concerns  sterilization. In its infamous 1927 decision in <a href=\"https:\/\/caselaw.findlaw.com\/court\/us-supreme-court\/274\/200.html\" rel=\"noopener\"><em>Buck v. Bell,<\/em><\/a> the Court upheld the compulsory eugenic sterilization of the &#8220;mentally  defective&#8221; in a case involving a young woman named Carrie Buck. The Court stated that &#8220;three generations of  imbeciles are enough.&#8221;<\/p>\n<p>In 1942, however, in <a href=\"https:\/\/caselaw.findlaw.com\/court\/us-supreme-court\/316\/535.html\" rel=\"noopener\"><em>Skinner v. Oklahoma<\/em><\/a>, the Court \u2013  without overruling <em>Buck<\/em> \u2013 invalidated  a punishment of sterilization that was imposed upon some, but not all, types of  recidivist felons. In doing so, the  Court said that procreation is a fundamental constitutional right and must  therefore not be the subject of arbitrary deprivation.<\/p>\n<p>In a second line of cases, the Court has recognized the  right <u>not<\/u> to procreate, in decisions protecting the use of contraception  (<a href=\"https:\/\/caselaw.findlaw.com\/court\/us-supreme-court\/405\/438.html\" rel=\"noopener\"><em>Eisenstadt  v. Baird<\/em><\/a> and <a href=\"https:\/\/caselaw.findlaw.com\/court\/us-supreme-court\/381\/479.html\" rel=\"noopener\"><em>Griswold v. Connecticut<\/em><\/a>) as well as  abortion (<a href=\"https:\/\/caselaw.findlaw.com\/court\/us-supreme-court\/410\/113.html\" rel=\"noopener\"><em>Roe v. Wade<\/em><\/a>). In each of  these decisions, though the issue before the Court was the right to avoid  reproducing, the rhetoric of the Justices underlined the importance of allowing  people to choose <u>whether or not<\/u> to procreate. In other words, even though these particular  cases provided an entitlement not to reproduce, they did so on a theory that  encompassed both negative and positive choices in that domain.<\/p>\n<p>Based on these cases, lower courts that have confronted  probation conditions involving the use of contraception (e.g., conditions  requiring the surgical introduction of a temporary contraceptive) have  generally invalidated such conditions.  In doing so, they have concluded that the government did not demonstrate  that depriving the probationer of her option to reproduce was necessary to  serve a compelling governmental interest, the standard for reviewing  deprivations of fundamental constitutional rights. <\/p>\n<p>In one exceptional case, however, a state supreme court held  otherwise, approving an order not to procreate that had been imposed upon a man  convicted of failing to pay child support for his nine existing offspring.<\/p>\n<p><strong>The Texas Judge&#8217;s  Reasoning \u2013 and the Problems in His Logic<\/strong><\/p>\n<p>Notwithstanding the case law recognizing a fundamental right  to determine one&#8217;s reproductive life, Judge Baird asserted that this unusual  probation condition was an appropriate one.  He explained, first, that the law gives him a great deal of discretion  to set any reasonable probation condition.  Second, he stated that he could unquestionably have sentenced Salazar to  a prison term, during which she would not have been able to reproduce. Therefore, he suggested, he had effectively  imposed a less severe version of what would have been a permissible prison  sentence by ordering the probationer not to have a child.<\/p>\n<p>Before assessing the constitutional legitimacy of the  probation condition imposed, it is useful to take a closer look at the judge&#8217;s  own arguments. First, though Texas law  does give a judge considerable discretion in setting conditions of probation,  this fact does not relieve him of the obligation to obey the dictates of the  U.S. Constitution. If one may not  deprive a person of her right to procreate as punishment for a crime, then a  judge who does so has violated the law, regardless of what Texas statutes  purport to authorize. <\/p>\n<p>Second, on the question of Salazar&#8217;s not being able to  procreate inside a prison anyway, such an argument may prove too much. There are many things that one cannot do  inside a prison \u2013 including organizing a rally to protest an unfair law \u2013 that  do not thereby become fair game as a probation condition. <\/p>\n<p>The inability to procreate in prison is, to some degree, an  incidental byproduct of confinement. To  make it, instead, a deliberate and targeted intervention in an otherwise free  person&#8217;s life is quite a different matter.  Indeed, the death penalty incidentally eliminates a condemned person&#8217;s  ability to do anything, once dead, but this does not mean that every  deprivation that falls short of death (including compelled fasting, the removal  of limbs, or a refusal to permit any expression of ideas) is necessarily  acceptable.<\/p>\n<p>The judge&#8217;s assumptions about his authority to prohibit  Salazar from conceiving a child are therefore questionable. Nonetheless, we might ask, <em>should<\/em> a judge be able to order a person  not to conceive?<\/p>\n<p><strong>The Argument in Favor  of a Non-Procreation Probation Condition<\/strong><\/p>\n<p>From the perspective of a convicted felon, the option of  freedom with the no-procreation condition is likely to look much more appealing  than the alternative of incarceration.  Whether by design or not, either penalty would frustrate the convict&#8217;s  desire to reproduce during her sentence.  The choice would therefore appear simple: It is less aversive to live on the outside  for a decade and not conceive children (because of a direct order) than it is to  live in a prison cell for ten years and not conceive children (because of a  lack of opportunity). In fact, it is  possible that the particular probationer had no plans to have children and  therefore might view the probation condition as insignificant. Virtually no one, by contrast, would view ten  years in prison as an insignificant burden.<\/p>\n<p>From the point of view of society, moreover, incarcerating a  prisoner is extremely expensive. Some  estimate the cost at about six times that of probation supervision. Imprisonment is therefore arguably a  worthwhile proposition only if at least one of two conditions is met \u2013 either  the criminal&#8217;s act was so wrongful that inflicting retribution is a high  priority or the criminal poses an apparent danger to the population and must be  incapacitated. But Felicia Salazar \u2013 the  woman on probation in this case \u2013 does not appear to have acted out of malice  toward her daughter \u2013 she was instead passive in the face of her boyfriend&#8217;s  violence. For this reason, she seems a  poor candidate for harsh retribution, as the judge appeared to recognize in  imposing probation rather than imprisonment in the first place. For similar reasons, Salazar would be  unlikely to pose a threat to anyone.<\/p>\n<p>The only individuals whom Salazar might endanger, based on  her history, are dependent children in her care. Given her record of neglecting the needs of  her own child (who is now in foster care), however, no government official will  deem Salazar fit to become a foster parent or an adoptive mother in the near  future. Thus, the only potential means  by which she might inflict harm is by having her own child and then failing to  protect and care for that child.  Ordering her not to conceive and a bear a child, then, is not only less  harsh and much less expensive than incarceration, but it also seems more  closely to fit the incapacitation objective of the state with respect to her  particular crime.<\/p>\n<p><strong>The Difficulties with  the Argument for a Non-Procreation Probation Condition<\/strong><\/p>\n<p>To understand what might be wrong with a no-conception  condition of probation, one must look beyond the particular choice faced by  Salazar, who is \u2013 for the reasons articulated above \u2013 more likely to accept  than to complain about the no-procreation condition. One way to do that is to assume  hypothetically that in the next ten years, Salazar violates the condition at  issue and conceives. What happens then?<\/p>\n<p>One possibility is that Salazar discovers that she has  conceived and then seeks an abortion to destroy the evidence. In such a case, assuming that she would not  otherwise have terminated her pregnancy, the judge&#8217;s order has effectively  pressured a woman into aborting as a means of avoiding incarceration. This prospect will likely disturb anyone who  believes that the decision whether or not to continue a pregnancy belongs to a  woman, and it will undoubtedly also trouble those who oppose abortion on moral  grounds.<\/p>\n<p>To avoid this possibility, the judge might arrange for  routine or random pregnancy tests \u2013 just as some probationers are subject to  random drug testing. In such a case, an  abortion would not necessarily protect Salazar from the discovery of her having  conceived, because her hormone levels could expose the truth, even after  termination. This might remove (or at  least reduce) the incentive for her to terminate a pregnancy.<\/p>\n<p>But if Salazar did have an abortion, she could legitimately  ask why the judge would punish her for having conceived. That is, if \u2013 as the law currently provides \u2013  a woman may not be compelled to carry a pregnancy to term, then what purpose does  it serve to place Salazar in prison for conception if her abortion has  eliminated the potential of harm to a child whom she might have neglected? To put the matter differently, what business  does a judge have in ordering her not to conceive, rather than just ordering  her not to give birth?<\/p>\n<p>It is possible that the judge ordered Salazar not to  conceive to avoid the appearance of pressuring her to abort, but the  consequence is either to incentivize abortion nonetheless, or to be prepared to  incarcerate a woman after she has eliminated the possibility that she will  neglect her child in the future. And if  Salazar conceives but decides to remain pregnant, then placing her in prison is  unlikely to provide the most healthful environment for the optimal development  of her fetus. The order not to procreate,  in other words, creates many problems as soon as Salazar decides to violate  it. <\/p>\n<p>The judge might alternatively insist on Salazar&#8217;s use of a  contraceptive that can be implanted in or injected into her body (and thus  verified) such as a Depo-Provera injection or an IUD. Such an intervention, however, is physically  intrusive and may also give rise to unanticipated health consequences. For a judge to direct medical interventions  that are not in the <u>patient&#8217;s<\/u> best interests, moreover, might itself be  unconstitutional, under <a href=\"https:\/\/caselaw.findlaw.com\/court\/us-supreme-court\/494\/210.html\" rel=\"noopener\"><em>Washington v. Harper.<\/em><\/a><\/p>\n<p>And finally, it is not obvious why the judge cannot  accomplish the same child-protective objective (without regulating  reproduction) by requiring that any children Salazar does have be removed from  her custody. With such an obvious  less-restrictive alternative, the judge&#8217;s procreation probation condition  becomes even more questionable.<\/p>\n<p><strong>Better than Prison<\/strong><\/p>\n<p>Yet the original question still gnaws at us \u2013 how can it be  permissible to incarcerate a woman but impermissible to release her on  condition that she not have more children (whom she would be unfit to  raise)? This question reveals a hidden  assumption \u2013 currently accepted as uncontroversial by our legal system \u2013 that  prison sentences represent a legitimate baseline against which to measure  alternative penalties. When we conclude  that prison is so terrible that an order not to conceive seems &#8220;better&#8221; by  comparison, this conclusion should perhaps make us question our readiness to  incarcerate, rather than motivate us to approve of the probation  condition. <\/p>\n<p>Incarceration is an inappropriate baseline, particularly for  a person who has not acted maliciously and who does not pose much of a danger  to anyone. The loose fit between the  procreation probation condition and the government&#8217;s objectives seems  impressive only by comparison to the complete absence of fit between the  alternative of incarcerating Salazar for ten years and the objective of  preventing her from neglecting any more children. <\/p>\nThe lesson of Salazar&#8217;s case may therefore have less  to do with the right to procreate \u2013 the ground on which a court would likely  invalidate the condition if given the opportunity \u2013 than it does with the  routinely-violated fundamental right to be free from incarceration. Perhaps if we subjected infringements upon  this right to the strict scrutiny that it deserves, we might arrive at  attractive alternative means of addressing criminal behavior.\n<hr size=\"1\">\n<p class=\"authorfoot\">\n\n<!-- BEGIN AUTHORS FOOTNOTE -->\n<a name=\"bio\"><\/a>\n<i>Sherry F. Colb is Professor of Law and Charles Evans Hughes Scholar at Cornell Law School.  Her book, <i><em>When Sex Counts: Making Babies and Making Law<\/em><\/i>, is currently available on Amazon. <\/i>\n<\/p><\/span>\n<br><br>\n\n\n\n\n    <\/div><div class=\"was-this-helpful\">\n    <div\n            class=\"was-this-helpful__question-container\"\n            aria-labelledby=\"was-this-helpful__question\"\n            role=\"group\"\n    >\n        <span\n                id=\"was-this-helpful__question\"\n                class=\"was-this-helpful__question fl-text-lg-bold\"\n        >Was this helpful?<\/span>\n        <button\n                class=\"was-this-helpful__button fl-text-sm\"\n                aria-label=\"Yes\"\n                value=\"yes\"\n        >\n            <span class=\"was-this-helpful__button-text fl-text-bold\">Yes<\/span>\n            <i class=\"was-this-helpful__button-icon\">\n                <svg width=\"22\" height=\"22\" viewBox=\"0 0 22 22\" fill=\"none\" xmlns=\"http:\/\/www.w3.org\/2000\/svg\">\n                    <g id=\"thumbs-up\" 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