Abstract
On 1 August 1984, a tribunal in Creteil, some 30 kilometers outside of Paris, decided the landmark case of Parpalaix v. CECOS.1 The case was one of first impression for France and other foreign jurisdictions. A 22 year old widow, Corrine Parpalaix, had brought suit against the national federation of sperm banks to recover the sperm of her recently deceased husband. Corrine sought his sperm so she might have the child they had hoped to have while her husband was alive. Thus, was presented the first case world-wide of ''post-mortem insemination. The Parpalaix case bespoke something of the autumn to come. In September, a 21 year old Marseille woman, married and the mother of an 18 month old son, announced she was pregnant and would become the first surrogate mother2 in France; she was to receive a gift of some $8-10,000 for her motherhood.3 In October, the National Committee on Bioethics4 announced the results of its yearlong study of the same question. Surrogate motherhood was cur-
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