Bioethics Forum Essay
What’s Wrong with a Fertility Doctor Using His Own Sperm?
When Donald Cline opened a fertility medicine clinic in Indianapolis in 1979, infertility was a relatively new medical specialty. There were no big sperm banks, no online sites for choosing sperm donors by their physical or mental traits. Doctors usually found donors themselves, and most were medical students. Virtually all donations were anonymous, and patients were advised not to tell their children that the fathers who were raising them were not their biological fathers.
Several years ago a group of women filed a complaint against Cline with Indiana’s attorney general, saying that they had learned from a genetic testing website that they were half siblings, and that all of them had been conceived from sperm in Dr. Cline’s office. Cline originally denied using his own sperm to impregnate women who came to him for artificial insemination, but eventually he acknowledged that he had done so about 50 times. DNA testing confirmed he had fathered at least 48 children born between 1979 and 1986.
One of his biological daughters reported the group’s findings to local law enforcement. She was told that there was no law in Indiana against Cline using his own sperm to inseminate his patients. The only crime with which he could be charged was a felony, obstruction of justice for lying to state investigators, to which he pleaded guilty in December 2018. He was sentenced to jail for a year, but the sentence was suspended.
Although a doctor’s use of his own sperm is not a crime in Indiana – or most other states – it contravenes professional ethical norms. Moreover, Cline’s failure to inform his patients that he had used his own sperm to inseminate them violated their rights as patients. In general, patients have a legal right to give “informed consent” to any medical procedures performed on them. Informed consent includes the right to receive truthful information about anything that is materially relevant to their decision to accept or reject the treatment. Doctors may not withhold information because they think it could be upsetting to patients or incline them to refuse treatment that the doctor thinks is necessary. A doctor’s failure to get informed consent from a patient could be the basis for a medical malpractice suit, if the patient has been injured.
Were Cline’s patients injured by what he did? Cline might claim that, on the contrary, he benefited his patients. He increased their chances of getting pregnant, since he was using fresh sperm, which at the time had higher success rates than frozen sperm. It would have been extremely difficult to obtain fresh sperm from donors, since this would require coordinating the schedule of the sperm donor with the ovulation cycle of each patient.
Even if Cline did increase some patients’ chances of achieving a pregnancy, it was unethical not to inform his patients about using his own sperm. Many of them have expressed shock and emotional distress at learning what he did. One of his patients, now aged 66, says, “I feel like I was raped 15 times.” There can be damages for emotional distress unrelated to physical injury in medical malpractice, depending on jurisdiction. However, the harm must be both objectively discernable and severe. This may be difficult to prove.
Another conceivable basis for a medical malpractice suit is that Cline deprived patients of meaningful choices of physician and treatment. Had the couples been told what Cline intended to do, at least some likely would have gone to a different doctor for artificial insemination. His deception was clearly ethically unconscionable. Whether it could result in a successful action for malpractice is unclear. To my knowledge, none of Cline’s patients have filed malpractice suits against him. However, in Indiana, several people sired by Cline are lobbying state legislators to create a new crime – “fertility fraud” — that would punish the intentional misuse of reproductive material with up to two and a half years in prison.
Several of the donor-conceived children have filed civil lawsuits against Cline, claiming that they have been harmed by what he did. Some of them relay shock at learning that Cline is their biological father. One of the children worries that she might have “inherited the DNA of a man who would lie to his patients and abuse his position as a doctor.”
Others are upset to discover that they have multiple half siblings. Moreover, there could be more they do not know about. One has wondered, “Did you [Cline] really think . . . that we wouldn’t meet? That we wouldn’t maybe date? That we wouldn’t have kids who might date? Did you never consider that?” It is not clear whether fathering 50 children in a city the size of Indianapolis actually created a risk of consanguinity, that is, that the offspring might unknowingly marry and have children. Nevertheless, the possibility that this could have occurred, or might occur with their children, was very upsetting to some of them. If the children suffered emotional harm as the result of what Cline did, shouldn’t the children, as well as the parents, have a cause of action against Cline?
What makes the lawsuits of the children Cline sired problematic is the fact that, but for Cline’s use of his own sperm, none of these children would have existed. This is an example of what philosophers call the nonidentity problem. Had Cline used sperm donors, the resulting children would not be the people who are claiming that Cline wronged them. They would be different people, born from different sperm. In light of this, can they claim that they were harmed by what he did?
There are three possible takes on the nonidentity problem as it pertains to this case.
The first is to say that Cline did nothing wrong with the respect to the children he sired. Any claim by the children that he harmed them stems from a failure to realize the nonidentity problem. That is, the children are thinking that, if Cline had used anonymous sperm donors to inseminate their mothers, they would have been born anyway, and they would not have suffered emotional harm. They are simply wrong about this. The only way to prevent the emotional harm would have been to prevent their births. On this view, as long as the children do not wish they had never been born, they cannot claim that they have been harmed by what Cline did. And if they were not harmed, Cline did nothing wrong, as far as the children are concerned.
Philosopher Jeffrey Reiman takes a very different approach. In his view, the children are right to think that Cline harmed and wronged them (at least if their emotional distress is severe enough to constitute a harm), and this claim does not stem from a misunderstanding about identity. Rather, Reiman says, choices about procreation should be made from the Rawlsian perspective of the original position where identity is irrelevant. The question potential procreators must consider is, “What kind of life is the child likely to have?” Potential procreators have an obligation to any future children to avoid bringing them into the world in a seriously harmful condition. It does not matter who the children are. Cline violated the children’s rights if he brought them into the world in a seriously harmful condition, when he could have avoided this by using sperm from anonymous donors.
In my view, Reiman is partly right and partly wrong. He is right about how people ought to think prospectively about procreation. Cline’s failure to think about effects on the future children he created is an important part of the reason why what he did was morally wrong. But I do not agree with Reiman that the children were wronged by Cline. How can the children maintain that Cline wronged them? Given that they are glad to be here, they cannot plausibly wish that Cline had acted differently, since this would entail that they had never been born. A claim of rights violation that is completely severed from a wish that the wrongdoer had acted differently is hard to comprehend.
A more plausible approach, and the one that I take, is to acknowledge that Cline’s behavior was immoral, unethical, and blameworthy, but not a violation of the children’s rights. If there are to be any medical malpractice suits against Cline, these should be limited to the parents, not the children. Nevertheless, public outrage at his behavior is entirely appropriate, and the medical profession was justified in taking away Cline’s license and preventing him from ever practicing again.
Bonnie Steinbock, a Hastings Center Fellow, is a professor emeritus of philosophy at the University at Albany/SUNY.
Author might have also mentioned the discovery in the late 1980’s and 1990’s of the University of California Irvine Medical Center where the doctors not only used their own sperm but also randomly and without informing clients used sperm from other couples. The law suits went on for many years, may still be ongoing for all I know, and shattered lives. The doctors, who were from South America, I believe, fled there and hid from US Justice.
courts should throw this stuff out and refuse to judge this. The couples or families wanted children and the doctors and medical students saw the pain of not being able to conceive every time they saw the patients. There was nothing criminal in any of them going on and fertilizing the egg to relieve the pain and suffering of their clients who could not conceive! In fact, it was probably as close to Christ and it gets. They saw peoples lives being impacted by not being able to conceive and they gave what was needed for the children to come into the world. if any of the fathers were deceived I imagine they wanted the kids so badly at that point that they went on and raised them as their own. I have known men who where sterile. It is like a madness to them that they are denied children. so no doctor or medical student should ever be taken to court for bringing some one the joy of a child. perhaps the child even saved some souls from drastic measures like suicide. I do not think there was any thing sinister in these doctors and medical students willing to provide healthy living sperm to an egg. who ever brought them to court should realize they would not be here if the man had not been thoughtful enough to fertilize the egg. from client perspective they come to the doctors for help to get a child. I would say the doctor went beyond the call of duty to make sure that the couple or woman got a living child. those sueing should be grateful for their lives and for some one willing to take the extra time to make sure they got here. because even then the doctor had to risk the insemination process and if that is true above there was a lack of men donating at the time and the only thing available was some one already interested in fertility science, I really do not see why any one is complaining. it just a nasty society we live in that takes every thing dirty and nasty and evil. and if that was not the intent of the doctors or medical students then it should just be left alone and judges say you know the client went to get a child and they did. i doubt the doctors or medical students charged extra for the service. the people upset should find some one today that can not conceive and talk in depth with them. Those doctors saw people daily and listened to their agony. To be honest unless you were totally money driven I doubt you could resist either. and courts should see it that way. and stop trying to punish all the time when there is nothing but compassion in this one.
The doctors deceived their patients. This is like getting the wrong product you paid for. This harms everybody. A bait and switch is not acceptable no matter how the medical profession tries to justify it. No one would tolerate getting the wrong piece of furniture they ordered. What makes it ok to get the wrong biological children? Many doctors have breeched their trust by depriving fathers of their own children by substituting thier own samples, Used samples in storage without peoples permission or used patients samples on other patients. Are you saying because families are desparate it is ok for a doctor to be unethical and take advantage of their patients? There needs to be rules and consequences for not following them. Laws need to be changed and everything needs to be open and honest. Greed needs to be taken out of the equation. The rights of the child need to come first before the parent or the medical profession. People should have the basic right to know who they are and to be able to access medical history and know that they are not going to marry a sibling by mistake since some donors are fathering hundreds of children.
Going along with the ethics argument mentioned along with other things in the article plus the previous comment, there seems to definitely have been ethical and medical obligations that were not available to all parties. Even if the patients were clear about consenting to the procedure, the source and suitability of the sperm leading to insemination apparently was not assured by adherence to ethical protocol. Certainly being the donor and provider for the patients without them knowing appears to be a violation of patient privacy and professional ethics. There’s probably much more that could be discussed including any motives by the provider. This seems like one of those things you would not expect to happen but as such recalls Murphy’s Law with a hefty dose of good old human nature.
Bonnie Steinbock is correct in her criticism of Reiman’s view that the children were wronged. The key point is: “Given that they are glad to be here, they cannot plausibly wish that Cline had acted differently, since this would entail that they had never been born.” Some years ago I was on a radio call-in show discussing the ethics of post-menopausal women using assisted reproduction to have children. A common criticism of that practice was harm to the future children who would have superannuated parents. In response, I made Steinbock’s point criticizing Reiman. Then a caller was on the air and said he had been unhappy as a child of “older parents.” When asked if that meant he wished he had never been born, he said “Yes.”
FIRST: Of course he behaved unethically. People who are putting their bodies and their biographies in the view and influence of a medical practitioner expect that there is nothing beyond the provision of medical care occurring as their relationship. Couples and individuals seeking donor fertilization generally have a wish to be in no relationship with the donor as a person. To be unknown to the donor and not know the donor. To see no one else in their child but themselves and any partner participating in their rearing. SECOND: The Offspring have an objection that avoids the non-identity problem. To wit: their claim would not be that they were injured by being the product of the doctor’s gamete, but that they were injured by his using one donor in a small community that would create the risk of consanguinity, and having the complications—e.g. fewer prospective safe sexual and/or relational partners in your community and the practical impossibilities of determining who those would be—and anxieties associated with the risk. The damage wasn’t directly to who they were, but to the environment they would live in. FURTHER, that with such a single donor, and especially given the controversial nature of that donor being the doctor himself, that there was a greater likelihood that the donor would not remain anonymous, and that they would come to know not only that their apparent father was not their biological father, but know in a concrete way that for human beings in general, would be difficult to ignore. Learning that they were the result of a donor sperm might still allow them to regard that donation as a blank placeholder. A specific person becomes a fact with meaning that has a non-trivial likelihood of intruding negatively in their established relations and lives.
On reading my prior comment, I can see that I went too far in avoiding expressing my strong aversion and contempt toward the physician’s behavior, and failed to name the specific kind of relationship which patients (and their partners whenever there was one) would be expecting to exclude from the provision of medical care: sex. In what they should have been able to expect, the provisions would be separating/distinguishing and distancing of sex from the reproductive nature of the donor fertilization procedure. It is credible to do this when the donor doesn’t know, has never seen, and will never know the person receiving the donation. Nor does the recipient have any knowledge of the donor. In the next step, the physician would be merely providing the technological and medical care portion of the procedure. It is nearly impossible to accomplish this conceptual and emotional isolation from the sex of the donor, when the donor is the physician and it is the doctor’s own sex that is involved. He becomes more of a participant as a progenitor. He knows the recipient as a person and has interacted in intimate ways with her body. He may identify the child on encountering them later in life in a small community (or even in a large community, the point being that the child would not be unidentifiable to the donor). The most disturbing intrusion of this re-sexualization of the encounter of the patient with her physician is when considering the likelihood of exactly what and who he was thinking about while he masturbated to produce the “fresh” sperm sample for a specific patient he knew to be coming in. I apologize deeply for the distress that thinking of this scenario may occasion, but it’s necessary to “flesh out” with all the injurious emotional implications of this, in order to appropriately consider the magnitude of harm as well as damages which patients can credibly claim. As with public officers obligations, it would not be dispositive what was or wasn’t actually in his mind, the harm of the appearance of sexuality in a relationship which it is established, and something he knew or should have known, must not include sex, is enough for strong sanctions and definite remedies.
If you feel that our life is not worth living as it is but would definitely be worth living with a million dollar payout then would you have a case?
On the other hand, Cline could claim to have not only provided them with a life that they could not have had, but also, to have – admittedly unintentionally, but almost perfectly – provided them one of the key accouterments of modern life, outrage.
In some of these cases, there is another party that has been severely harmed: the husbands/partners of women who believed that their sperm would be used in the insemination process. These men have been fraudulently deprived of their (biological) fatherhood. Further, the couplehood of the man and woman in these cases has been violated by the MDs – they have displaced the male in the couple by discarding their semen and using their own. This violates the rights of both the man and woman, and cannot result in anything but pain and distress for the couple to address. I don’t think this aspect of the violation gets the attention it deserves.
Could you imagine being in a relationship/marriage with someone, and then finding out your bio father used his sperm and created life for 50 other people in your town? You don’t think you’d be a little nervous that you were in a relationship with someone you might be related to? Knowing who your family is typically discourages people from dating their own family members. But if you don’t know that you’re the product of some unethical doctors decision to use his own sperm for procedures (because your parents didn’t know either), then you don’t know there’s 50 people out there you probably shouldn’t date… Thinking of being in that kind of situation, with a potential of dating a half sibling from your town/region and not knowing it, is understandably upsetting.
The case described in this piece is particularly interesting because it represents an instance in which the incidence of ethical wrongdoing is clear, but the legal recourse is less straightforward. At the time, it seemed that Dr. Cline’s conduct did not neatly fall under prosecutable civil or criminal law; as a result, he was only charged with obstruction of justice for deception surrounding his activities, which did not constitute legal accountability for the acts themselves—an understandable disappointment for his victims. Cline’s ethical transgressions can be framed in terms of the core principles of bioethics. In the first place, he violated the principle of non-maleficence in that he ultimately brought harm upon his patients. Though Cline might argue that he was trying to promote what was “good” for his patients (beneficence) by allowing them to realize their parental aspirations (and thereby promoting their wants), this end could have been accomplished by other means. Moreover, this assumes an overly general view of what these patients actually wanted—framed as “having a child”—whereby a more specific, accurate framing of their wishes might instead be “to have a child not biologically related to their physician.” Alternatively, this defense perhaps misconstrues a woman’s desire to have a child and willingness to turn to assisted reproductive technology with the desire to be inseminated with any man’s sperm; and, if given the choice, his patients would likely not judge their desire to have a child worthwhile if only possible via the use of Cline’s gametes. Finally, fulfilling someone’s present wishes may be perceived as beneficial to them in the short-term, however, could constitute a harm in the long-term.
An additional source of harm brought about by Cline’s conduct involves the risk of consanguinity due to the large number of offspring that he facilitated in a particular area, who might unknowingly marry and procreate together. More generally, this might raise the question of whether there should be uniform limits on gamete donations from an individual, as well as whether children produced through gamete donation should eventually be informed of their genetic parents’ medical history. One reason for this is to promote individual awareness to decrease the risk of consanguinity. In any case, recipients of anonymous gamete donation are at least entitled to be honestly and robustly informed of the medical history of the donor.
In the present case, a large proportion of Cline’s offspring ultimately developed auto-immune disorders, potentially attributable to his rheumatoid arthritis (ironically, which would have excluded him from eligibility as a donor in his clinic) [1]. However, it is unclear whether we can establish if Cline harmed his offspring (either (1) emotionally, by making the circumstances of their birth controversial or by possibly increasing their chances of entering into incestuous relationships, or (2) physically by passing on unpleasant medical conditions). That is, we might wonder whether a person can be harmed by an action that underpins his or her own existence. Professor Steinbock claims that “as long as the children do not wish they had never been born, they cannot claim that they have been harmed by what Cline did.” However, even if the children do not retroactively affirm their existence as worthwhile—e.g., they do wish they had never been born—we might wonder whether this sentiment has actual significance; plausibly, this can only meaningfully signify that they feel their lives are no longer worth living, not that it would preferable to them never to have been brought into existence, as this is something we cannot even conceptualize as an alternative.
Still, though we may not necessarily wrong people by bringing them into a physically or psychologically harmful existence, this does not mean that we have no moral responsibilities toward future persons. Professor Steinbock maintains that “potential procreators have an obligation to any future children to avoid bringing them into the world in a seriously harmful condition.” This works as a private, ethical consideration, but is likely not legally enforceable; additionally, I am not sure I agree that this would constitute a “rights violation.” It might be, though, that the “harmful condition” indicated here is a sort of incorrigible harm or intrinsic property of the child’s existence (rather than, for instance, a harmful external circumstance, like poverty); still, this perhaps raises a question on the flip-side as to whether there is a “most moral” way to bring children into the world based on an absence of seriously harmful conditions and/or an abundance of “beneficial” conditions, and what the criteria for this would be.
Cline also violated the principle of respect for persons, or autonomy, in that he undermined his patients’ ability for provide informed consent for the insemination by deliberately withholding information about the source of sperm, which would have likely made a difference to their decisions. Although the patients consented to receive an anonymous sperm donation, Cline told them that it would be collected from a medical resident who would only facilitate successful pregnancies in at most three women [1–4] (Cline obviously did not meet this criteria, given his professional qualifications at the time, as well as the fact that he went on to father dozens of children in this manner—as of May 2022, he has been confirmed as the genetic father of 94 offspring) [1, 5]. Additionally, even if Cline had been forthcoming about his intention to use his own sperm, arguably, his patients still would not be able to consent to using it, given the asymmetrical power distribution between physician and patient and the unique vulnerabilities of the patient (e.g., in the same way we acknowledge that “a patient cannot give meaningful consent to sexual contact with his or her physician due to the position of trust and the disparity of power in the patient-physician relationship” [6]).
Although, at the time, Indiana had no formal laws against fertility fraud, some possible avenues for legal recourse (both criminal and tort) have been proposed for this case [1–4]. Because the women consented to the artificial insemination procedure, it would be difficult to prosecute Cline’s acts as sexual assault in the traditional sense. In addition, Cline might defend his actions against claims of sexual assault by arguing that they were clinical in nature, rather than sexual: that even though his process of obtaining a sample of sperm was sexual, the insemination itself (which presumably took place in a separate room, at some later time) was part of a technical professional assignment [2–4]. However, given the large number of inseminations performed with his own sperm, as well as his deception surrounding the matter, it is not unreasonable to suppose that there was a pathological sexual motive underpinning Cline’s conduct, as opposed to merely convenience, or financial or biological (i.e., the perceived advantage of using fresh sperm over frozen sperm at that time) motives.
Because the women were unaware that Cline was substituting his own sperm, it has been suggested that his conduct is a “rape by deception”—involving sexual conduct only brought about under false pretenses, for instance, where one party deceives another (the victim) into agreeing to sexual acts that they would not have consented to had they not been deceived [2–4]. However, this can be difficult to prosecute in some cases; the concept itself evokes questions about what degree of deception would be required to classify a sexual encounter of this kind as rape (so as to avoid slippery slope arguments positing that anything short of a full disclosure of one’s identity and intentions in sexual encounters constitutes rape by deception).
Another proposed legal avenue for this case is medical battery, or the intentional “harmful and offensive touching” of another person in a medical setting without their permission [1–4]. Cline’s use of his own sperm to inseminate his patients without their knowledge is a violation of their dignity that would qualify as “offensive.”
Additionally, Cline can be argued to have committed fraud in the inducement (inducing another into entering an agreement by misrepresenting a material fact) insofar as he lied and actively misrepresented the identity and quality of the sperm he was offering to patients (although his deception was for the source of the sperm and not the insemination act itself, his patients did not just agree to the insemination procedure, they were agreeing to the more specific condition that they would be inseminated using gametes from an anonymous medical resident) [2–4, 7]. Furthermore, he equivocated about the agreed upon condition of anonymity: typically, this is a reciprocal arrangement, whereby recipients do not know the personal identity of the donor, and vice versa. However, in Indiana, medical records must be kept for at least seven years after the date of service, whereas Cline’s insemination fraud was not discovered until decades later, at which point evidence of his misrepresentation, and of what he told patients and what they agreed to, was no longer available [4, 8].
Finally, it is also difficult to demonstrate the applicability of “intentional infliction of emotional distress” (IIED) as a civil charge in this case. Although Cline’s conduct—which went against the standard of care at that time, in addition to being ethically perverse—was clearly “extreme and outrageous” and caused “severe emotional distress” to his patients later on, Cline might argue that he did not “intend” to inflict emotional harm (and that he, rather, was trying to promote their wellbeing by helping them achieve their aspirations of parenthood) [1–4, 9]. Moreover, he might assert (though this is not so believable) that he was unaware of the of the potential for his patients to discover what he had done, which might qualify his behavior as negligence; however, this still does not rise to the level of recklessness (awareness of risk, but with conscious disregard) required for IIED [10].
Instances of fertility fraud that escaped legal prosecution have since prompted legislative action in several jurisdictions. The Protecting Families from Fertility Fraud Act of 2023 (H.R. 451) is a bill proposing to establish a “new federal criminal offense for knowingly misrepresenting the nature or source of DNA used in assisted reproductive technology or assisted insemination,” with violations subjected to fines and/or a prison term of up to ten years [11]. Although this bill has not yet been passed, a number of states have enacted their own legislation; these may be analyzed to ascertain what elements ought to be incorporated into fertility fraud laws. For example, such laws should include a statute of limitations that takes into consideration the fact that most victims to not uncover the incidence of fertility fraud until decades after it occurs [12]; this has been accomplished in Indiana, under Indiana Code Title 34 Civil Law and Procedures § 34-11-2-15, which states that:
“(a) Except as provided in subsection (b), an action for civil fertility fraud (IC 34-24-5) must be commenced not later than:
(1) ten (10) years after the eighteenth birthday of the child; or
(2) if subdivision (1) does not apply, twenty (20) years after the procedure was performed.
(b) An action for civil fertility fraud that would otherwise be barred under this section may be commenced not later than five (5) years after the earliest of the date on which:
(1) the person first discovers evidence sufficient to bring an action against the defendant through DNA (deoxyribonucleic acid) analysis;
(2) the person first becomes aware of the existence of a recording (as defined in IC 35-31.5-2-273) that provides evidence sufficient to bring an action against the defendant; or
(3) the defendant confesses to the offense” [13].
There is also a question as to whether any civil action should be compensatory or punitive, or both. One case for penalizing the defendant is that it may be an effective deterrent for other fertility specialists. Furthermore, should there be a criminal component? This might echo the sentiment of rape articulated by the patient quoted in Professor Steinbock’s writing; however, how should this be incorporated legally? Should we develop a new, separate term, or expand existing sexual assault laws? (For example, in 2020, Florida created a “reproductive battery” felony: if the healthcare provider acts as a donor of reproductive material, knowing the recipient has not consented to its use, this is considered a second-degree felony, punishable by up to fifteen years in prison [1, 14]. On the other hand, in 2019, Texas passed a bill to recognize fertility fraud as a sexual assault felony [1, 4].) These are just a few questions up for consideration as legislation against fertility fraud is hopefully continued to be passed to protect patients around the country.
Works Cited
1. Garofalo, Megan Resener. “Fertility fraud in the land of Lincoln: why Illinois must pass comprehensive legislation to address donor fraud in artificial insemination.” DePaul L. Rev. 73 (2023): 91.
2. Madeira, Jody Lynee. “Uncommon misconceptions: holding physicians accountable for insemination fraud.” Law & Ineq. 37 (2019): 45.
3. Madeira, Jody Lynee. “Holding Physicians Accountable for Fertility Fraud.” forthcoming Columbia Journal of Gender and Law (Spring 2020), Indiana Legal Studies Research Paper (2019).
4. Madeira, Jody Lyneé. “Understanding illicit insemination and fertility fraud, from patient experience to legal reform.” Colum. J. Gender & L. 39 (2020): 110.
5. Wallace, Lindsay Lee. 2022. “The True Story Behind the Netflix Documentary ’Our Father’”. Time. Time. May 12, 2022. https://time.com/6176310/our-father-true-story-netflix/.
6. American Academy of Orthopaedic Surgeons. n.d. “Opinion on Ethics and Professionalism: Sexual Misconduct in the Physician-Patient Relationship.” https://www.aaos.org/contentassets/6507ec63e5ac4ea48375ad96d154daac/1208-sexual-misconduct.pdf.
7. “Fraud in the Inducement”. Legal Information Institute. Legal Information Institute. https://www.law.cornell.edu/wex/fraud_in_the_inducement.
8. “Medical Records Retention Laws by State”. 2022. Cariend. September 12, 2022. https://www.cariend.com/medical-records-retention-laws/.
9. “Intentional Infliction of Emotional Distress”. Legal Information Institute. Legal Information Institute. https://www.law.cornell.edu/wex/intentional_infliction_of_emotional_distress.
10. McDuffey, Ty, JD. 2023. “Recklessness.” FindLaw. 2023. https://www.findlaw.com/injury/accident-injury-law/recklessness.html#:~:text=Recklessness%20involves%20conduct%20less%20than,they%20should%20have%20been%20aware.
11. Congress.gov. “H.R.451 – 118th Congress (2023-2024): Protecting Families from Fertility Fraud Act of 2023.” January 24, 2023. https://www.congress.gov/bill/118th-congress/house-bill/451.
12. Chicoine, Sarah. “The birth of fertility fraud: how to protect Washingtonians.” Wash. L. Rev. Online 95 (2020): 168.
13. “Indiana Code Title 34. Civil Law and Procedure § 34-11-2-15.” 2024. FindLaw. January 2, 2024. https://codes.findlaw.com/in/title-34-civil-law-and-procedure/in-code-sect-34-11-2-15/.
14. Trachman, Ellen. 2020. “Reproductive Battery: A New Crime For A New World”. Above the Law. Above the Law. July 8, 2020. https://abovethelaw.com/2020/07/reproductive-battery-a-new-crime-for-a-new-world/.