The Story of Madrigal v. Quilligan: Coerced Sterilization of Mexican-American Women

Abstract

This essay tells the story of Madrigal v. Quilligan, an unpublished decision from a California federal district court refusing to remedy sterilization abuse in the early 1970s.

After a whistleblower leaked evidence of rampant sterilization abuse at the Los Angeles County USC Medical Center, ten women (the Madrigal Ten) filed a lawsuit alleging that medical personnel systematically coerced Mexican-American women into submitting to sterilization. The case dramatically altered public consciousness and public policy on coerced sterilization. Despite their loss in the damages phase of the litigation, the Madrigal Ten served as the catalyst for California’s strengthened regulations for ensuring voluntary consent to sterilization. In addition, the Madrigal litigation also inspired the anti-sterilization abuse movement in California and helped to shape Chicana feminism in the 1970s. The case galvanized Chicana feminist activism in ways that highlighted tensions between mainstream white feminists and women of color. The Chicana activists working on the Madrigal matter used multiple strategies to achieve their policy goals. They relied not only on the litigation of the case itself, but also lobbied for legislative reform and engaged in public education, including through widespread media attention. The activists brought the still nascent framework of reproductive justice to the forefront, incorporating concerns about discrimination along intersectional lines of gender, race, poverty, and immigration status — all issues at play in the Madrigal case.

The essay also explores how the story of Madrigal v. Quilligan still resonates today. The threat of sterilization abuse continues to loom for vulnerable populations, particularly poor women and women of color.

Keywords: sterilization, sterilization abuse, coerced sterilization, Madrigal v. Quilligan, eugenics, abortion, long-acting reversible contraception (LARC), Chicana feminism, reproductive justice, reproductive rights, informed consent, constitutional law, health law