## Facts

- Multiple actions were consolidated in federal district court challenging federal regulations governing sterilization funded through federal family-planning programs administered by the Department of Health, Education and Welfare (HEW).
- Plaintiffs included individual women and a class of poor persons alleged to be subject to involuntary sterilization under the challenged regulatory scheme, along with a welfare-rights organization suing on behalf of its members.
- Defendants were the HEW Secretary and senior officials responsible for administering family-planning funding under federal health and welfare statutes.
- The suit arose amid documented instances of sterilization abuse involving low-income patients, including coercive practices and deficient consent procedures.
- Congress authorized federal funding for a “full range” of family-planning services through public health and welfare programs, while requiring that participation be voluntary; the statutory text did not expressly mention sterilization.
- Before the challenged 1974 regulations, there were no detailed federal rules specifying when sterilizations could be funded or what consent safeguards were required.
- Plaintiffs sought declaratory and injunctive relief, arguing that the regulations permitted funding of sterilizations without adequate assurance of voluntary, informed, uncoerced consent, including for minors and persons lacking mental capacity.
- The matter was presented on cross-motions for summary judgment and a motion to dismiss or for summary judgment; HEW deferred the regulations’ effective date to permit judicial review.

## Issues

1. Whether federal family-planning statutes authorizing only voluntary services permitted HEW to fund sterilization procedures under its programs.
2. Whether HEW had statutory authority to fund sterilizations for individuals legally incompetent to provide informed, voluntary consent due to minority or mental incapacity.
3. Whether the challenged regulations were arbitrary and unreasonable for failing to ensure informed, uncoerced consent and to prevent coercion tied to receipt of public assistance.

## Decision

- The court largely ruled for plaintiffs and against HEW.
- The court held the Secretary lacked statutory authority to fund sterilizations for persons incompetent to consent because voluntariness could not be satisfied for those legally unable to provide informed, voluntary consent to an irreversible procedure.
- The court found the regulations arbitrary and unreasonable to the extent they did not adequately ensure that sterilizations funded under federal programs were voluntary and based on informed, uncoerced consent.
- The court enjoined HEW’s use of federal funds for sterilizations of certain incompetent persons and required amendment of the regulations to implement the statutory requirement of voluntariness and to bar coercion.
- After the decision, HEW withdrew the challenged regulations and indicated it would issue replacements; subsequent proceedings treated the controversy as moot and remanded for dismissal.

## Legal Principles

- Federal funding for family-planning services is conditioned on the patient’s voluntary request; agency rules must implement that statutory limitation.
- An agency administering family-planning funds lacks authority to finance sterilization of persons legally incompetent to provide informed, voluntary consent absent clear congressional authorization.
- Because sterilization is irreversible and implicates the right to procreate, consent safeguards must be robust and must exclude procedures based on legally invalid consent.
- Regulations governing federally funded sterilizations are unlawful if they are arbitrary and unreasonable for failing to ensure informed, uncoerced consent and for failing to prohibit coercion, including pressure linked to welfare eligibility or benefits.

## Conclusion

The district court invalidated core aspects of HEW’s sterilization regulations, holding that federal family-planning statutes required genuine voluntariness and informed consent and did not authorize funding sterilizations of persons incompetent to consent; it enjoined funding in those circumstances and required regulatory changes to prevent coercion and ensure valid consent.


Relf v. Weinberger, 372 F. Supp. 1196 (D.D.C. 1974)