Madrigal vs. Quilligan

The Case

    Madrigal vs Quilligan is a court case that was filed in 1975 by ten plaintiffs. The accusations consisted of forced sterilization over multiple decades and manipulation by the doctors in order to get consent from the patients. The case also brought race into the equation because doctors took advantage of language barriers and also expressed prejudice against many immigrant women. Many of these women were not told of what the operation they were signing for and were mislead by the doctors into thinking that the procedure would benefit their health. Doctors also told the patients that the procedure would be reversible, which was incorrect information.


    Lying behind all of the doctors and judges many people believed that there were racial stigmas were forced upon these women, which were part of the reason that they were sterilized. Doctors were even quoted taunting women of color in labor with pain medication if they would sign the tubal ligation papers. Doctors were even heard threatening the life of the children that had just been born if the patient didn’t sign the papers. Although no motives of race were ever proved in court, it is thought that the thinking of the doctors and the hospitals were aligned with the Neo Eugenics movement and the idea of ridding the country of all of its burdens. These women were seen as burdens because they were seen by others as wanting to come here to have their kids and then live off of US taxpayer dollars. Although these accusations were not true, many people of color and immigrants were forced into these condition by the climate of post WWII United States.

The Outcome

    The court case came to a close in 1978 where judge Jesse Curtis ruled that none of the accusations by the women were true and that “This case is essentially the result of a breakdown in communications between the patients and the doctors.” The court viewed what happened as a misunderstanding rather than an action by the doctors with malicious intent. The court believed that their dramatization of sterilization was caused by their difference in cultural background to other American citizens and that this disconnect was not the doctors fault but the women themselves faults. The court also ruled that there was no intent by the doctors to deliberately hurt these women, which is arguably incorrect as exemplified by the quotes below.

The Importance

    Although the hospital won the case, some progress was still made. Madrigal was able to help change the state laws to require Spanish translations of the sterilization booklet. They also were able to get the California Department of health to create a seventy-two hour waiting period for sterilization.

Los Angeles County Hospital USC

    One of the largest hubs of mass sterilization in California was Los Angeles. The film No Más Bebes highlights the injustices done to thousands of immigrant women at Los Angeles County Hospital USC. Women would come into the hospital to give birth and the doctors would force them to get an irreversible operation which prevented them from having more children. Many of the women could not speak or read English yet all of the consent forms would be written in English and the doctors did not speak Spanish. Doctors would take the opportunity to ask the mothers, who were often panicking while in labor, to have an operation which they thought would save their own lives, or the life of the baby. The mothers would give birth and have no idea that it was the last child that they could ever have. In many cases, the doctors would make it seem that they could not operate at all unless they signed the paper thereby giving informed consent, and for someone about to give birth, this is terrifying. These fear tactics were used on nearly 20,000 women of color in California in the 1960’s through the 1970’s.

Questions to Consider

  • What are the racial and ethical implications of sterilizing immigrant women without their knowledge or consent?

  • What do you think the motivation behind the forced sterilization was?