Anti-Choice groups invoke forced surgery to justify Georgia’s abortion ban

Rainbow Pro-Life Alliance and Secular Pro-Life should reflect upon what it says about their organizations that they’ve chosen to invoke 'Jefferson' and about the possible consequences of doing so.

The State of Georgia is fighting a challenge to its abortion ban. On December 10, 2024, Rainbow Pro-Life Alliance and Secular Pro-Life submitted an amici curiae brief in support of the State of Georgia. The brief invokes a case of forced surgery to justify Georgia’s abortion ban.

Part 1: Background information

• SisterSong v. Georgia

• Superior Court ruling

• State of Georgia appealed

Part 2: The amici curiae brief

• The right to bodily integrity

• Jessie Mae Jefferson and forced surgery

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PART 1: Background information

❇️ Sister song v. Georgia

Georgia’s abortion ban (The Life Act) prohibits abortions once embryonic cardiac tones are detectable by an ultrasound. Due to the variability in the length of people’s menstrual cycles,¹ month-to-month variations in the timing of ovulation,² and implantation bleeding,³ many people don’t realize that they are pregnant until after embryonic cardiac tones are detectable.

On July 26, 2022, SisterSong Women of Color Reproductive Justice Collective filed a state constitutional challenge to Georgia’s abortion ban. The lawsuit asserts that the ban “violates the Georgia Constitution’s robust protection for the fundamental right to privacy, which is independent of the U.S. Constitution.”⁴

SisterSong is a Southern-based organization that works “to improve institutional policies and systems that impact the reproductive lives of marginalized communities.”⁵ The organization works toward ensuring that women of color and other marginalized women have access to contraception, sex education, prevention of and care for sexually transmitted infections, birth options, prenatal and pregnancy care, domestic violence assistance, safe homes, abortion, and the adequate wages necessary to support their families.⁶

❇️ Superior Court Ruling

On September 30, 2024, a Republican-appointed judge for the Superior Court of Fulton County, the Honorable Robert C.I. McBurney, ruled in SisterSong Reproductive Collective v. State of Georgia that Georgia’s abortion ban is unconstitutional under the Georgia’s Constitution. The ruling came shortly after news broke of the deaths of two Georgia women. Amber Nicole Thurman and Candi Miller “died after they couldn’t access legal abortions and timely medical care in their state.”⁷ Georgia’s Maternal Mortality Review Committee directly linked Candi Miller’s death to Georgia’s abortion ban.⁸ The ruling returned Georgia’s abortion law to what it had been before Roe v. Wade was overturned, which prohibited abortions once a fetus was capable of sustaining life outside of the uterus.

In his ruling, Judge McBurney wrote, “Whether one couches it as liberty or privacy (or even equal protection), this dispute is fundamentally about the extent of a woman’s right to control what happens to and within her body. The baseline rule is clear: a legally competent person has absolute authority over her body and should brook no governmental interference in what she does -- and does not do -- in terms of health, hygiene, and the like. Cruzan v. Director, MDH, 497 U.S. 261, 269 (1990) (‘Every human being of adult years and sound mind has a right to determine what shall be done with his own body’).”

“[D]oes a Georgian’s right to liberty of privacy encompass the right to make personal healthcare decisions? Plainly it does. See, e.g., State v. McAfee, 259 Ga. 579 (1989); Zant v. Prevatte, 248 Ga. 832 (1982).”

Therefore, wrote Judge McBurney, “Because the LIFE Act infringes upon a woman’s fundamental rights to make her own healthcare choices and to decide what happens to her body, with her body, and in her body, the Act must serve a compelling state interest and be narrowly tailored to achieve that end. State v. Jackson, 269 Ga. 308, 310 (1998). The Act fails the second half of that two-part test: there is nothing narrow about a law so blunt that it forces a woman to allow a fetus grow inside her for months after she has made the difficult and deeply personal decision not to bring the pregnancy to term. Indeed, as the trial testimony made clear, the Act’s prohibitions against certain healthcare choices take effect before most women even know they are pregnant and so before they can begin to contemplate whether having a child is safe and sustainable for the mother and, if relevant, for her family.” “[T]he record is [] clear,” he wrote, “that for many women, their pregnancy was unintended, unexpected, and often unknown until well after the embryonic heartbeat began. Yet that’s too late under the LIFE Act’s strictures: these women are now forbidden from undoing that life-altering change of circumstances -- before they even knew the change had occurred.”

According to Judge McBurney, “the LIFE Act criminalizes a woman’s deeply personal and private decision to end a pregnancy at a time when her fetus cannot enjoy any legislatively bestowed right to life independent of the woman carrying it. Put differently, the uncontroverted evidence from the trial of this case is that a pre-viability fetus survives only through the woman choosing -- or being forced by law -- to carry it at least to the 22nd or 23rd week of her pregnancy.” “Pre-viability,” he wrote, “the best intentions and desires of society do not control, as only the pregnant woman can fulfill that role of life support for those many weeks and months. The question, then, is whether she should now be forced by the State via the LIFE Act to do so? She should not. Women are not some piece of collectively owned community property the disposition of which is decided by majority vote. Forcing a woman to carry an unwanted, not-yet-viable fetus to term violates her constitutional rights to liberty and privacy, even taking into consideration whatever bundle of rights the not-yet-viable fetus may have.”

“For these women,” Judge McBurney continued, “the liberty of privacy means that they alone should choose whether they serve as human incubators for the five months leading up to viability. It is not for a legislator, a judge, or a Commander from The Handmaid’s Tale to tell these women what to do with their bodies during this period when the fetus cannot survive outside the womb any more so than society could -- or should -- force them to serve as a human tissue bank or to give up a kidney for the benefit of another. Considering the compelling record evidence about the physical, mental, and emotional impact of unwanted pregnancies on the women who are forced by law to carry them to term (as well as on their other living children), the Court finds that, until the pregnancy is viable, a woman’s right to make decisions about her body and her health remains private and protected, i.e., remains her business and her business alone. When someone other than the pregnant woman is able to sustain the fetus, then -- and only then -- should those other voices have a say in the discussion about the decisions the pregnant woman makes concerning her body and what is growing within it.”

“While the State’s interest in protecting ‘unborn’ life is compelling, until that life can be sustained by the State -- and not solely by the woman compelled by the Act to do the State’s work -- the balance of rights favors the woman,” he declared.

❇️ Ruling Appealed

The State of Georgia appealed Judge McBurney’s ruling.

On October 7, 2024, at the request of Georgia’s Attorney General Christopher Carr, the Supreme Court of Georgia unanimously blocked Judge McBurney’s ruling from being in effect for the duration of the State’s appeal. Hence, Georgia’s strict Life Act currently remains in effect.

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PART 2: The amici curiae brief

On December 10, 2024, two anti-choice groups, Rainbow Pro-Life Alliance (formerly known as the Pro-Life Alliance of Gays and Lesbians) and Secular Pro-Life, submitted an amici curiae brief in support of the State of Georgia, in which the groups invoke forced surgery to justify Georgia’s abortion ban. But forced surgeries diverge from “every concept and principle upon which our society is founded.”⁹ So, before discussing the anti-choice groups’ amici curiae brief, let’s review the rights of American citizens in regards to medical treatment and intrusion upon and into the body.

❇️ The right to bodily integrity

“The right to bodily integrity is protected by the Fourth and Fourteenth Amendments to the United States Constitution.”¹⁰ In fact, “the right to protect one's own body from the invasion of others is, perhaps, an individual's most significant privacy right.”¹¹

The United States Supreme Court, in Winston v. Lee, “refused to force a robbery suspect to undergo [surgery]. The court held that the proposed surgery would violate the respondent's right to be secure in his person. Surgery without the patient's consent, performed under a general anesthetic involves ‘virtually total divestment’¹² of the patient’s ‘ordinary control over surgical probing beneath his skin.’”¹³

American law “imposes no general duty to aid others.”¹⁴ There are a few exceptions to this rule for “special relationships,” such as “that of parent and child,”¹⁵— but “[e]ven in instances where ‘a special relationship gives rise to a duty to rescue, there is still no duty to undertake risky rescues.’ A limited number of states have created a statutory duty to rescue, but they require ‘only such assistance as can be rendered without danger to the rescuer.’”¹⁶

“[C]ourts will not intervene and require the parent to provide health-risking assistance,”¹⁷ because, “to require risky rescues, even by a parent, would mean a drastic revision of this country's laws."¹⁸ “Parents are not required to risk their health and safety, as through” surgery or through “an organ transplant, to benefit their child, or even to save the child's life;”¹⁹ and “courts do not order a refusing adult to submit to organ donation for the benefit of another.”²⁰

In McFall v. Shimp, a court refused to order a defendant, Mr. Shimp, to donate bone marrow to save the life of his cousin, Mr. McFall. “Bone marrow extraction is not major surgery, but it is painful.”²¹ In McFall, the “court emphasized there is no legal duty to give aid to another, and stated that to require such a duty ‘would change every concept and principle upon which our society is founded."²²

The question posed… is that, in order to save the life of one of its members by the only means available, may society infringe upon one's absolute right to his "bodily security"? The common law has consistently held to a rule which provides that one human being is under no legal compulsion to give aid or to take action to save another human being or to rescue. A great deal has been written regarding this rule which, on the surface, appears to be revolting in a moral sense. Introspection, however, will demonstrate that the rule is founded upon the very essence of our free society… Our society, contrary to many others, has as its first principle, the respect for the individual, and that society and government exist to protect the individual from being invaded and hurt by another… In this case, the chancellor is being asked to force one member of society to undergo a medical procedure… so that the other could live… For our law to compel [Mr. Shimp] to submit to an intrusion of his body would change every concept and principle upon which our society is founded. To do so would defeat the sanctity of the individual, and would impose a rule which would know no limits, and one could not imagine where the line would be drawn. (McFall v. Shimp)

To reiterate: The Constitution of the United States of America “provides a competent individual the right to refuse unwanted medical procedures.”²³ This right is “imbedded in the notion of informed consent; physicians are prohibited from performing medical procedures on a patient without consent, and the failure to gain consent is considered battery.”²⁴ This right is also “based on common law and the constitutional concepts of an individual's right to bodily integrity, self-determination, and privacy.”²⁵ This “right to bodily integrity is protected by the Fourth and Fourteenth Amendments to the United States Constitution,” and this “right to protect one's own body from the invasion of others” is “an individual's most significant privacy right.”²⁶

No person forfeits this right upon becoming pregnant. Even with the best of intentions, attempting to nullify the constitutional rights of a pregnant person through forced surgery is to offend “every concept and principle upon which our society is founded.”²⁷

The following example is illustrative.

Imagine, for a moment, that a very obese, recalcitrant father has “securely wedged [himself] in the door[way], and gaining access to [his] sick child to provide treatment required cutting through the father.”²⁸ No court would force the father to submit to this. During pregnancy, “access to the fetus occurs through the body of the pregnant woman.”²⁹ As such, “any fetal intervention has implications for the pregnant woman’s health and necessarily her bodily integrity.”³⁰ It therefore should never be performed “without her explicit informed consent,”³¹ just like intervention for a sick child should never involve cutting through a father's body without his consent.

❇️ Jessie Mae Jefferson and forced surgery

The amici curiae brief filed by Rainbow Pro-Life Alliance and Secular Pro-Life seeks to undermine SisterSong’s argument regarding the right to privacy (right to bodily integrity) under Georgia’s Constitution. To do this, the brief appeals to three cases, the first one being Jefferson v. Griffin Spalding County Hospital Authority (1981).

In Jefferson, after a pregnant woman named Jessie Mae Jefferson exercised her rights by declining to consent to a cesarean operation, the Juvenile Court of Butts County granted the State of Georgia custody of the woman's fetus, as well as the “full authority,” on behalf of the fetus, to consent to surgery upon its mother's body. In effect, when the court granted the State custody of the fetus, the woman's body became the property of both the fetus and the State— and being property, the State was free to dispose of her body as the State saw fit. The all-male Georgia Supreme Court upheld the lower court's decision, and Jessie Mae was taken to the hospital for preoperative tests and cesarean surgery.

As I have written about before, beginning in the 1980’s, anti-abortion groups “took public interest in… forced caesareans as an opportunity to expand fetal rights.”³² American’s United for Life, for example, worked with hospitals to compel cesarean surgeries through court orders.³³

In what is perhaps the most disturbing case, In re A.C., “a court ordered the performance of a caesarean section upon a terminally ill woman. The procedure was calculated to hasten the woman's death, yet to increase the fetus' chances for survival.”³⁴ The court disturbingly reasoned that "although in some cases the surgery will result in the mother's death,... The child, on the other hand, [might survive] delivery.”³⁵ “Surgery was ordered over the objections of the patient, her husband and her family. The fetus died within two hours of the surgery." The patient's death followed within two days. The caesarean section was listed as a contributing cause of the young woman's death.”³⁶

In another case, a pregnant woman who declined to consent to cesarean surgery was detained against her will with leather wrist and ankle cuffs attached to the four corners of a bed while she frantically screamed for help.³⁷

As discussed above, “no court would require a [parent] to undergo major surgery for the benefit of a born child no matter how serious the potential consequences of refusal.”³⁸ Yet these women were compelled to undergo major surgery for the benefit of the fetus, with at least one woman dying as a result.

“The American system of rights is individualized— premised on the concept of singular, physically separate, and autonomous people.”³⁹ Though a fetus is a part of the pregnant person, anti-choice activists insist the pregnant body contains two wholly separate and rights-holding people. Yet, American “law has no framework for two rights holders in one body,” and under the radical Fetal Personhood ideology “if the law has no framework for two rights holders in one body, then the pregnant person must be something else entirely. She becomes less of a [person] and more of an object— a reproductive vessel, merely the container for another individual rights-holder.”⁴⁰ “Through her objectification, the… pregnant person is rendered ineligible for the [same and equal] rights” as all other citizens, and thus vulnerable to state violence.⁴¹ As researchers have observed:

First, if fetuses are full, legal people, and the law cannot comprehend “two physical bodies” that “occupy the same place at the same time,” then the [] pregnant person must not truly be a person – but something else. Next, if [] pregnant people are not fully human – not legal subjects – then they are instead objects or reproductive vessels. Finally, if [] pregnant people are objectified as reproductive vessels, then they are vulnerable to the same types of violence that all dehumanized and objectified people have been subject to across time and history.⁴²

Court-ordered surgery is state violence. It also sets a terrible precedent. “When the courts make unwise decisions, those decisions become legal precedent and, consequently, affect many people. Furthermore, ‘[a]cceptance of forced caesarean sections, hospital detentions and intrauterine transfusions may trigger demands for court ordered prenatal screening, fetal surgery, and restrictions on the diet, work, athletic activity, and sexual activity of pregnant women.’ Threats to a woman's privacy in these forms should not be considered unimaginable. Once courts have allowed major surgery to be performed against a woman's will, these more subtle restrictions will most likely be viewed as ‘less invasive and burdensome.’"⁴³

While many people believe that a pregnant person “has a moral duty to provide the best possible care for her developing fetus, the transformation of that moral duty into a legal duty creates many consequences.”⁴⁴

Not only does forced medical intrusion upon, into, and within a pregnant person’s body “change every concept and principle upon which our society is founded,”⁴⁵ there also are very real physical and emotional consequences— consequences that must be born by the pregnant person, and the pregnant person alone. For example, “courts have forced women to submit to blood transfusions and caesarean sections to benefit their fetuses. Women who are reluctant to follow medical advice have been detained in hospitals until the birth of their fetuses. Results such as these violate the woman's right to privacy and bodily integrity,”⁴⁶ and diminish her humanity and status as an equal, rights-holding citizen.

Jessie Mae Jefferson’s birth story didn’t end with the court order. Unlike other pregnant people subjected to state violence, Jessie Mae ended up giving birth vaginally to a healthy 7-pound, 3-ounce girl.⁴⁷ — But the abhorrent precedent set by the Georgia Supreme Court in Jessie Mae’s case lives on.

Rainbow Pro-Life Alliance’s and Secular Pro-Life’s joint amici curiae brief invokes Jefferson - a case of court-ordered violence that belongs in the dust bin of history - to justify Georgia’s abortion ban. Rainbow Pro-Life Alliance and Secular Pro-Life should reflect upon what it says about their organizations that they’ve chosen to appeal to Jefferson and about the possible consequences of doing so. “For our law to compel [a person] to submit to an intrusion of his body would change every concept and principle upon which our society is founded. To do so would defeat the sanctity of the individual, and would impose a rule which would know no limits, and one could not imagine where the line would be drawn.”⁴⁸ Even with the best of intentions, to nullify the constitutional rights of a pregnant person through forced surgery, as Jefferson does, is to offend “every concept and principle upon which our society is founded.”

1. “For most women, a normal menstrual cycle ranges from 21 to 35 days.1 However, 14% to 25% of women have irregular menstrual cycles, meaning the cycles are shorter or longer than normal.”

U.S. Department of Health and Human Services. (n.d.). What are menstrual irregularities?. Eunice Kennedy Shriver National Institute of Child Health and Human Development. https://www.nichd.nih.gov/health/topics/menstruation/conditioninfo/irregularities#:~:text=For%20most%20women%2C%20a%20normal,from%2021%20to%2035%20days.&text=However%2C%2014%25%20to%2025%25,other%20problems%2C%20like%20abdominal%20cramps.

2. “Most women ovulate anywhere between Day 11 – Day 21 of their cycle, counting from the first day of the LMP.” “Ovulation can occur at various times during a cycle and may occur on a different day each month.”

Editor. (2023, September 20). What is ovulation?. American Pregnancy Association. https://americanpregnancy.org/getting-pregnant/infertility/understanding-ovulation/

3. "Spotting or bleeding may occur shortly after conception, this is known as an implantation bleed. It is caused by the fertilised egg embedding itself in the lining of the womb. This bleeding is often mistaken for a period, and it may occur around the time your period is due."

NHS. (2018, May 31). Bleeding and/or pain in early pregnancy. Hull University Teaching Hospitals NHS Trust . https://www.hey.nhs.uk/patient-leaflet/bleeding-andor-pain-early-pregnancy/

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12. Divestment: to deprive, as of rights or property

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45. Mcfall v. Shrimp, available at https://bioethics.jhu.edu/wp-content/uploads/2024/08/McFall-v-Shimp-1978-7.pdf

46. Trindel, Robin M. (1991) "Fetal Interests vs. Maternal Rights: Is The State Going Too Far?," Akron Law Review: Vol. 24 : Iss. 3 , Article 9. Available at: http://ideaexchange.uakron.edu/akronlawreview/vol24/iss3/9

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