## Facts

- Ten Mexican-origin women, primarily Spanish-speaking and recent immigrants, gave birth at a Los Angeles public hospital between roughly 1968 and 1974 and later underwent tubal ligations, often during or immediately after cesarean deliveries.
- Plaintiffs alleged the sterilizations were performed without voluntary, informed consent, including use of English-only forms, inadequate translation, and timing when patients were in labor or otherwise medically distressed.
- Plaintiffs alleged coercion and misrepresentation, including statements that sterilization was medically required, threats of harm to mother or child if they refused, and assurances that the procedure was temporary or reversible.
- Plaintiffs asserted they were subjected to disparaging comments suggesting their children would be burdens on public resources.
- Defendants included the chair/director of obstetrics at the hospital and other physicians and officials; defendants asserted consent was obtained, procedures were medically justified, and there was no policy targeting Mexican-origin women.
- Plaintiffs presented expert testimony that laboring patients cannot give intelligent, knowing consent and that sterilization carried heightened cultural and psychological consequences for the patient group.

## Issues

1. Whether defendants, acting under color of state law, deprived plaintiffs of Fourteenth Amendment liberty interests in bodily integrity and reproductive decision-making by performing sterilizations without voluntary, informed consent.
2. Whether plaintiffs proved an Equal Protection violation by showing intentional discrimination or a purposeful policy targeting Latina, low-income, Spanish-speaking patients for sterilization.
3. Whether deficient consent practices attributable to language barriers and hospital practices could support § 1983 liability absent proof of deliberate coercion or discriminatory intent.

## Decision

- After a bench trial, the district court entered judgment for defendants on the federal constitutional and § 1983 claims.
- The court characterized the dispute as arising from a breakdown in communication between patients and physicians rather than a deliberate plan to sterilize Mexican-origin women.
- The court found insufficient evidence of an intentional, racially motivated policy or conspiracy to deprive plaintiffs of constitutional rights.
- The court treated consent problems as misunderstandings or individual errors, not intentional constitutional violations.
- The Ninth Circuit affirmed the judgment without a published opinion.

## Legal Principles

- § 1983 liability for alleged Fourteenth Amendment violations generally requires proof of intentional or deliberate deprivation of federal rights, not merely negligence, misunderstanding, or poor communication.
- Equal Protection claims require proof of purposeful discrimination; disparate outcomes or troubling anecdotes, without adequate proof of intent or policy, may be insufficient.
- In evaluating informed-consent-based constitutional claims, documented written or recorded consent may be treated as legally sufficient absent clear proof of coercion, force, or intentional deprivation.
- Recognition of reproductive choice interests does not, by itself, establish federal damages or injunctive liability for defective consent processes without sufficient proof of intentional state action to suppress reproduction.

## Conclusion

The federal courts rejected plaintiffs’ § 1983 challenge to postpartum sterilizations at a public hospital, finding inadequate proof of intentional discrimination or a purposeful coerced-sterilization policy and treating the consent failures primarily as communication and language-related errors rather than constitutional violations; the Ninth Circuit affirmed without opinion.


Madrigal v. Quilligan, 639 F.2d 789 (9th Cir. 1981)