by preventing the ‘‘mentally defi cient’’ from
reproducing; the victims were dispropor-
tionately Black women and Native American
women. In California, more than 17,000 were
sterilized between 1920 and 1945 under a state
eugenics law used to prevent reproduction of
those deemed ‘‘unfi t’’; a disproportionate num-
ber were women of Mexican descent. In 1976,
a study by the U.S. General Accounting Offi ce
found that between 1973 and 1976, four of the 12
Indian Health Service regions sterilized 3,406
Native American women without their permis-
sion, including three dozen who were under
- Also in 1976, H.E.W. reported that over 37
percent of Puerto Rican women of childbearing
age, most in their 20s, were sterilized between
the 1930s and the 1970s. The U.S. government
had taken an active role in population control
beginning in 1898, when it assumed governance
of Puerto Rico, on the supposed grounds that
overpopulation would increase poverty and
other social and economic conditions.
Eventually, because of the Relfs’ case and oth-
ers, the congressional investigations and journal-
ists reporting on them found that thousands of
poor, mostly Black women were sterilized each
year in the United States under federally funded
programs. Many others were coerced into ster-
ilization when health care providers threatened
to cut off their benefi ts unless they agreed to
give up their fertility. The Relfs’ suit ended these
practices, and H.E.W. was forced to withdraw
regulations under which the government funded
forced sterilizations. The federal government alsoinstituted a requirement that health care provid-
ers obtain informed consent before performing
sterilization procedures — more than the X Min-
nie Relf had signed.The Relf case happened almost 50 years ago, in
another century, and many people would prefer to
see it as a dark moment in history that could never
happen now. But coerced contraception, includ-
ing sterilization, has continued into the 21st centu-
ry. In 2013, the Center for Investigative Reporting
found that physicians under contract with the Cal-
ifornia Department of Corrections and Rehabil-
itation sterilized nearly 150 female inmates from
2006 to 2010 without required state approvals for
the tubal ligations the women received. According
to the reporting, prison staff coerced or pressured
women they believed likely to return to prison.
State documents and interviews pointed to some
100 more procedures dating back to the late 1990s:
‘‘From 1997 to 2010, the state paid doctors $147,460
to perform the procedure, according to a database
of contracted medical services for state prison-
ers,’’ C.I.R. reported.
In 2017, Judge Sam Benningfi eld of White
County, Tenn., was reprimanded for promising
30-day sentence reductions to incarcerated men
and women who agreed to receive vasectomies
or birth-control implants. Benningfi eld claimed
he was trying to encourage personal responsibil-
ity and prevent incarcerated people from being
burdened with children when they were released.
The A.C.L.U. chapter in Tennessee said in a state-
ment at the time that ‘‘off ering a so-called ‘choice’
between jail time and coerced contraception or
sterilization is unconstitutional.’’ In the fall of
2020, a nurse at a for-profi t Immigration and Cus-
toms Enforcement detention center in Georgia
reported that unnecessary gynecological proce-
dures — including hysterectomies — had been
performed on undocumented migrant women.
The women said that they had undergone the
operations without fully understanding or con-
senting to them. The Times reported that Dr. Ada
Rivera, medical director of the ICE Health Ser-
vice Corps, said that the whistle-blower’s claims
‘‘raise some very serious concerns that deserve to
be investigated quickly and thoroughly.’’
These cases demonstrate the persistent vul-
nerability of incarcerated and detained women
in the criminal-justice and immigration systems.
But even after the Relf case led to changes in laws,
regulations and guidelines regarding forced or
coerced sterilization, the question of compen-
sation for the victims has remained. The federal
lawsuit was not the only one fi led on behalf of the
Relfs themselves: Levin and Dees recruited Mel-
vin Belli, nicknamed the King of Torts — and Mel-
vin Bellicose by insurance companies — to fi le a
damages suit to compensate the family. Loud and
outrageous, Belli was best known for his celeb-
rity clients: Errol Flynn, Mae West, Lana Turn-
er, Lenny Bruce, Zsa ZsaPhotograph by Hannah Price for The New York Times The New York Times Magazine 35
Mary Alice (left) and Minnie Lee
at home in May.(Continued on Page 46)