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A Latinx Resource Guide: Civil Rights Cases and Events in the United States

1981: Madrigal v. Quilligan

"Under the severe pain of labor, and after being assured that the operation could be easily reversed, she signed these forms and was sterilized."

—Antonia Hernandez

Rachael Romero, artist. Stop forced sterilization. 1977. Library of Congress Prints and Photographs Division.

Madrigal v. Quilligan was a civil rights class action lawsuit filed by 10 Mexican American women against the Los Angeles County-USC Medical Center for involuntary or forced sterilization. The plaintiffs involved in Madrigal v. Quilligan were residents of East Los Angeles, a predominantly Latinx population with inadequate medical and educational resources. Unauthorized sterilizations among Mexican women with minimal English proficiency rose at the County Medical Center during the 1970s. Among the victims were Dolores Madrigal, who claimed that doctors pressured her into signing a sterilization consent form while she was in labor, and Jovita Rivera, who signed the concession document without being counseled on the consequences of sterilization.

Dr. Bernard Rosenfield, a young physician at the county General Hospital, acted as the whistleblower by exposing testimony on the doctors’ malpractice on low income and minority women. Dr. Rosenfield requested the legal services of Model Cities Center for Law and Justice, where lawyers Antonia Hernandez, Georgina Torres Risk, and Richard Navarette managed the case. The lawyers collaborated with Comisión Feminil, a feminist organization led by Gloria Molina and argued their case on the basis of Roe v. Wade, claiming that women possessed the reproductive rights to procreate and to an abortion.

The California federal court under Judge Jesse W. Curtis ruled in favor of the county medical center and held that sterilizations were the result of miscommunication and language barriers between the patients and the doctors. Despite losing the case, the plaintiffs influenced the California Department of Health to implement new sterilization procedures, including bilingual informational materials that explained the process and consequences of sterilization. The State of California also revoked their sterilization law, which had enabled over 20,000 unauthorized sterilization operations to occur.

Timeline

January 22, 1973 Roe v. Wade secures womens’ rights to abortions without governmental interference.
October 12, 1973 Doctors sterilize Dolores Madrigal without authorization during the labor of her second child.
July 1976 10 women file a class action lawsuit against the Los Angeles County-USC Medical Center.
June 7, 1978 Judge Jesse W. Curtis rules in favor of the defendants, stating that miscommunication and language barriers resulted in unwanted sterilizations.

Resources

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