Forced Sterilization Research Articles

"Mere guesswork": Clarifying the role of intelligence, mentality, and psychometric testing in the diagnosis of "mental defectives" for sterilization in Alberta from 1929 to 1972.

From 1929 until 1972, the Alberta Eugenics Board (the Board) recommended that 4,739 individuals be sterilized. The original 1928 act that legalized eugenic sterilization stipulated that the surgery itself required the consent of the individual or their caregiver; however, in 1937, the Alberta government removed the consent requirement for such cases where the Board determined individual patients to be "mental defectives." By analyzing published reports, case histories, medical journals, and primary sources from the Board, we situate the concept of "mental defective" in a historical context to clarify the Board's diagnostic process. By analyzing how the Board found individuals to be "mental defectives," we challenge a previous historiographic assumption that intelligence tests played a critical or defining role in this diagnostic process. We argue that the notion of the "mental defective" used by the Board had a long history before the advent of intelligence testing and eugenic thought. This history helps to explain how and why the Board relied extensively on the broader examination of behavior, social status, and physical appearance as core evidence in the diagnosis of "mental defect." Intelligence tests were certainly important as they shed light on an individual's academic ability. However, this alone was only one part of "mentality." Defects of mentality were understood to be broad and multifactorial, and included difficult, if not impossible, to measure attributes such as personality, emotionality, and morality. Further research should incorporate the concept of mentality in the history of psychology, testing, and eugenics. (PsycInfo Database Record (c) 2023 APA, all rights reserved).

Berthold Kihn (1895-1964) and the NS "Euthanasia": Profile of a Perpetrator

In historical sciences, there is no consensus on how to understand the transition from eugenic sterilization to "euthanasia". The aim of this article was to investigate this question based on the historical-critical method, using the example of the perpetrator profile of Berthold Kihn. His pseudoscientific way to "euthanasia", however, did not have an eugenic foundation. Literature- and archival studies were carried out. For the first time, attention was paid to relevant Franconian and familial archival sources. Moreover, documents of the Jena University Archive were compared to those of the concentration camps of Buchenwald and Oranienburg. After professional as well as private dilemma, the neuroinfectiologist Kihn set a focus on the "eradication of the inferiors". Apart from Kihn's role in central "euthanasia" and "childrens' euthanasia", which has been clearly demonstrated, we found actual hints of his additional involvement in decentral "euthanasia". This is shown using the example of the prominent patient Felix von Papen. Kihn was no racial hygienist, he did not make his mark as an eugenicist. His professional and private dilemma may - among other things - have motivated him, to join a politically promoted movement. Further comparative research in the profiling of NS perpetrators may contribute to a better differentiation of the transition from eugenics to "euthanasia".

MEDICAL, LEGAL, PHILOSOPHICAL AND SOCIO-ECONOMICAL PREREQUISITES OF DECREASE OF THE FERTILITY RATE IN EUROPE

During less than a century number of our population halved. Fertility rate in Europe as well as in the whole World decreases constantly. There are numerous prerequisites because of which we can observe an aforementioned tendency. We are emphasizing here namely medical, legal, moral, philosophical and socio-economical ones. Not to underestimate remain postulates that separate a vision that we deserve to reach as a society i.e. equity, equality, personal freedom, zero discrimination etc., and tendencies, biases and prejudices that slow us down every single day and make those goals impossible to reach with our current state of mind. On one hand, there is number of reasons which explain an actual decrease of fertility rate clearly enough. Among them we are emphasizing high level of domestic violence, violence against women, weak abortion legislation which enslaves human rights of women in most of European countries, and, therefore, voluntary or forced sterilization, child-free tendencies, moral traumas, victim syndromes because of personal weakness and inability to do as we/or particularly woman pleases to. Additionally, rich black market of illegal abortions which consequences are often lethal or acutely dangerous for a female reproductive system, alongside with female organs mutilations committed by perpetrators of domestic violence etc, all these prerequisites lead to a visible decrease of the statistics that were mentioned before. However, at the same time, the modernly promoted desire to “live one’s life in full”, to “enjoy life without special responsibilities being husband/wife/parent”, lack of desire to create a family “until the studies will be completed, house will be bought, financial stability will be reached, all dreams will come true and so on, also keeps the idea of family life and parenthood on distance, as individuals want to maximize their happiness and pleasure with minimizing worries and “pains” at the same time. In addition, because of child-free tendency lovers and children’s haters, along with childfree hotels, restaurants, flights and other services make parents actually into outcasts from the other “proper society, that knows how to live this life without worries”. Parents of small children cannot obtain some services, are limited from visiting some places (and most of the times not because of rational reason, but rather in the aim of protecting other people’s tranquillity), experience a high level of moral pain and feeling “non-normal” when their life is different from of those, who “properly knows what and how to do”. At the same time, we shall claim that as long as the parenthood become popular and societally accepted again, and will not be associated with becoming outcasts anymore, and as long as the abortion legislation will not be optimized and become pro-feminine, along with anti-violence practical tools of fighting with perpetrators, we will not be able to talk about successful overcoming of the fertility crisis in Europe.

Reproductive Justice and the Figure of the Child: The Multiple Harms of Forced Sterilization and Abortion in Peru.

AbstractWe argue that discourses around forced sterilization and abortion restrictions too often focus on motherhood and fertility and ignore the multiple other harms they bring. To do this, we travel with the North American framework of reproductive justice (RJ) to think through experiences of (non)reproduction in Peru and consider its analytic possibilities. In this intervention, we wish to focus on the commonality between RJ's three tenets: the figure of the child and its analytic force. We argue that while the aim of the RJ framework is not to reify fetuses and children at the expense of adults nor to reinforce a pronatalist position, the fact that the tenets are formulated around children means that, when mobilized for political or analytical purposes, they can reinforce repronormative mandates. We use the examples of forced sterilization and abortion in Peru to consider the issues this figuration of the child brings into being and the landscape of meaning it produces.

A CASE STUDY OF CAT STERILIZATION IN KARANGWUNI, YOGYAKARTA: IMPACTS PERCEIVED BY CARETAKERS AND THEIR UNDERSTANDING OF THE PROGRAM

There is yet to be collected the number of cats in Indonesia, including free- roaming cats. Studies have shown that there is a connection between sterilization and free-roaming cats’ health and welfare. In 2021, Suara Suaka Indonesia decided to hold a small-scale sterilization program in a neighborhood called Karangwuni, Yogyakarta to contribute in lowering cat population. In this case study, we focus on the effect of sterilization to cats that are perceived by humans. Survey was done using Google Forms, taking information on their demographics, involvement with Suara Suaka Indonesia, feedback on their cats’ post-surgery changes and their understanding on sterilization. Respondents are generally satisfied with the impact sterilization has on them and their cats, this is supported by how they perceive sterilization as important and their willingness to recommend the procedure to other people. However, there can still be improvement on delivering messages of sterilization to ensure that the purpose, process, and impact of sterilization can be adequately understood by all participants of the program.

Analisis Hukum Terhadap Tindak Pidana Kekerasan Seksual

Harassment is often perceived as deviant behavior, because the act forces someone to engage in a sexual relationship or establishes someone as an object of unwanted attention. That is, sexual harassment can be in the form of indecent behavior, such as touching vital body parts, or it can only be in the form of words or statements that are indecent. The method used in this research is normative research based on primary legal materials, secondary legal materials and tertiary legal materials. The technique used in collecting data is library research. And then analyzed descriptively. The results of this study indicate that sexual violence crimes consist of: a. non-physical sexual harassment, b. physical sexual harassment, c. forced contraception; d. forced sterilization; e. forced marriage; f. sexual abuse; g. sexual exploitation; h. sexual slavery; and i. electronic based sexual violence. Sexual Violence Crimes also include a. rape; b. obscenity; c. intercourse with children, obscene acts against children, and/or sexual exploitation of children; d. acts of violating decency that are contrary to the will of the victim; e. pornography involving children or pornography that explicitly contains violence and sexual exploitation; f. forced prostitution; g. criminal acts of trafficking in persons aimed at sexual exploitation; h. sexual violence within the household; i. money laundering crime whose predicate crime is a crime of sexual violence; j. other criminal acts that are expressly stated as criminal acts of sexual violence as regulated in the provisions of laws and regulations. The impact of violence on victims includes the following impact on physical or psychological health, impact on fulfilling women's human rights and social relations and economic impact.

Rebuilding a Reproductive Future Informed by Disability and Reproductive Justice.

Rebuilding a Reproductive Future Informed by Disability and Reproductive Justice.

Trap, Snip, Repeat: Cat Overpopulation and Gendered Labour in a Feral Sterilisation Programme

Cat overpopulation in Toronto, Canada, is a serious and growing problem. Small, and frequently isolated, groups of volunteers work in a variety of capacities to help mitigate the large numbers of litters produced by stray and feral cats. One such organisation is Toronto Street Cats. This volunteer group works with the help of the Toronto Humane Society to operate a monthly trap/neuter/release (TNR) programme. Groups of caretakers look after registered feral cat colonies and capture cats of breeding age. Once a month these cats are sterilised, vaccinated, treated for parasites, and microchipped in an evening-long marathon. Volunteers in veterinary medicine (registered veterinary technicians [RVTs], veterinary assistants and veterinarians) comprise the medical staff who provide treatment and perform the assembly-line surgeries. Post-surgery, the cats are taken by the volunteers to a recovery facility and

Применение автоматического парового стерилизатора для обеззараживания отходов иммунобиологического производства, контаминированных патогенными биологическими агентами

One of the ways to neutralize immunobiological production waste is their treatment in sterilizers with saturated water vapor under pressure. Currently, medical and pharmaceutical industries and laboratories use sterilizers with sterilization and disinfection programs preset by manufacturers. Decontamination modes are defined in Federal sanitary rules, norms and hygienic standards, SanPiN 3.3686-21, while the parameters of preliminary phases of the cycle must be tested experimentally and validated for specific conditions. Within the frames of this study, we have tested the modes of disinfection of an automatic steam sterilizer by the example of waste products from the production of cholera vaccine and anti-rabies immunoglobulin manufactured by the FSSI Russian Anti-Plague Institute «Microbe» of the Rospotrebnadzor. The wastes are used nutrient media, carcasses of laboratory animals (rabbits) and consumables. The chamber was loaded with «clean» objects in quantity and configuration, repeating the loading of material with pathogenic biological agents (PBA). The mode of inactivation inside the chamber and the objects was controlled by physical, chemical and biological methods. Based on the results of the experiments, corrective actions were taken to change the program and design of containers for autoclaving. It was concluded that the default disinfection programs set by manufacturers do not fully take into account specific conditions and need to be adjusted with further validation. It is necessary to develop standard operating procedures for personnel involved in the decontamination of pathogenic materials, in which should be stated the order of placement of objects and the means of control in the containers with PBA and the sterilizer chamber. Keywords: steam sterilizers, pathogenic biological agents, disinfection with saturated water vapor, phases of the steam disinfection cycle, validation.

Ghosts of eugenics’ past: ‘Childhood’ as a target for whitening race in the United States and Canada

ABSTRACT While in modernity childhood was increasingly invested with emotional and intellectual energy, it also became a site of scrutiny and intervention, so that philosophers, scientists, and humanitarians pursued the improvement of humanity and the human condition through management of ‘the child’. In the first half of the twentieth century, such attention settled on children deemed to present both problems and opportunities for the improvement of the race, as eugenics came to dominate discussions of human progress. This article examines the significance of childhood as a resource for human futures and technologies of ‘eugenics’ insofar as they target children: specifically, the development of intelligence testing, institutions of separation, and involuntary sterilization in the United States and Canada. In these discourses and technologies of eugenics, childhood appears as a reserve of human potential which, appropriately regulated, may be harnessed to ‘build a better future’. The article also considers the perspective of survivors of these practices who experienced their childhood and future possibilities as having been expropriated from them by the state. By considering these governmental and personal registers side by side, the article sheds light on the perceived social utility of childhood, as well as the particular character of loss experienced by those whose childhoods were subject to state intervention.

Racialization and Reproduction: Asian Immigrants and California's Twentieth-Century Eugenic Sterilization Program.

During the twentieth century, state health authorities in California recommended sterilization for over 20,000 individuals held in state institutions. Asian immigrants occupied a marginalized position in racial, gender, and class hierarchies in California at the height of its eugenic sterilization program. Scholars have documented the disproportionate sterilization of other racialized groups, but little research exists connecting the racist, gendered implementation of Asian immigration restriction to the racism and sexism inherent in eugenics. This study examines patterns of coercive sterilization in Asian immigrants in California, hypothesizing higher institutionalization and sterilization rates among Asian-born compared with other foreign- and US-born individuals. We used complete count census microdata from 1910 to 1940 and digitized sterilization recommendation forms from 1920 to 1945 to model relative institutionalization and sterilization rates of Asian-born, other foreign-born, and US-born populations, stratified by gender. Other foreign-born men and women had the highest institutionalization rates in all four census years. Sterilization rates were higher for Asian-born women compared with US-born [Incidence Rate Ratio (IRR)=2.00 (95% CI: 1.61, 2.48)] and other foreign-born women (p<0.001) across the entire study period. Sterilization rates for Asian-born men were not significantly higher than those of US-born men [IRR 0.95 (95% CI 0.83, 1.10). However, an inflection point model incorporating the year of sterilization found higher sterilization rates for Asian-born men than for US-born men prior to 1933 [IRR 1.31 (95% CI 1.09, 1.59)]. This original quantitative analysis contributes to the literature demonstrating the health impact of discrimination on Asian-Americans and the disproportionate sterilization of racial minorities under state eugenics programs.

HF01-04 THE VIRGINIA STERILIZATION ACT: A CATALYST FOR AMERICAN EUGENICS

You have accessJournal of UrologyCME1 Apr 2023HF01-04 THE VIRGINIA STERILIZATION ACT: A CATALYST FOR AMERICAN EUGENICS Davis Moore, Theodore Cisu, and Adam Klausner Davis MooreDavis Moore More articles by this author , Theodore CisuTheodore Cisu More articles by this author , and Adam KlausnerAdam Klausner More articles by this author View All Author Informationhttps://doi.org/10.1097/JU.0000000000003243.04AboutPDF ToolsAdd to favoritesDownload CitationsTrack CitationsPermissionsReprints ShareFacebookLinked InTwitterEmail Abstract INTRODUCTION AND OBJECTIVE: The origins of the American eugenics movement are rooted in the Virginia Eugenical Sterilization Act of 1924. This set a historic precedent that led to the Supreme Court ruling in Buck v. Bell (1927), which legitimized sterilization to prevent the birth of more “defective” individuals. More than 3,000 men underwent forced sterilization via vasectomy in Virginia alone. METHODS: A review of historical and medical literature was undertaken, as well as analysis of academic texts on American sterilization and eugenics. RESULTS: In the early 20th century, an increasing number of physicians promoted forced sterilization of “feebleminded” men and women to prevent the propagation of undesirable character traits in American society. One notable early proponent of eugenics was Harvey E. Jordan, dean of the School of Medicine at the University of Virginia and president of the American Genetic Association. The movement gained support from other prominent physicians including acclaimed urologist and birth control advocate William J. Robinson who wrote the early seminal books on contraception, including Eugenics, Marriage, and Birth Control in 1917. Although the first eugenic sterilization law was passed in Indiana in 1907, it was not until the Virginia Sterilization Act of 1924 that the practice of eugenic sterilization was codified as a legitimate medical practice. In its historic Buck v. Bell decision of 1927, the Supreme Court ruled that forced sterilization did not violate the 14th Amendment. The case centered around Carrie Buck in Charlottesville, VA who was deemed “defective” and “feebleminded” after being raped by the nephew of her foster parents. She was institutionalized after giving birth, and later sterilized in October 1927 as a result of the Supreme Court decision. Over the next four decades, the rate of eugenic sterilization soared nationwide. Estimates of the number of men and women undergoing forced vasectomies and salpingectomies in Virginia range from 7,300 to 8,300 between 1924 and 1979, with historical estimates of more than 60,000 sterilizations across the US. The American eugenics movement has been credited with lending inspiration to Adolf Hitler and the architects of the Holocaust. CONCLUSIONS: Virginia remained the last state to practice eugenic sterilization, repealing the statute in 1974. More than 3,000 forced vasectomies were performed in the state, and tens of thousands others across the country. The now infamous Buck v. Bell decision has yet to be overturned. Virginia Gov. Mark Warner issued a formal apology in 2002 for Virginia’s embrace of eugenics for more than five decades. Source of Funding: N/A © 2023 by American Urological Association Education and Research, Inc.FiguresReferencesRelatedDetails Volume 209Issue Supplement 4April 2023Page: e257 Advertisement Copyright & Permissions© 2023 by American Urological Association Education and Research, Inc.MetricsAuthor Information Davis Moore More articles by this author Theodore Cisu More articles by this author Adam Klausner More articles by this author Expand All Advertisement PDF downloadLoading ...

Literary Bioethics: Animality, Disability, and the Human by Maren Tova Linett

<i>Literary Bioethics: Animality, Disability, and the Human</i> by Maren Tova Linett

Curiously Cured by Sterilization: Charles Carrington and the Sterilization of African American Men in Virginia, 1902–1910

This article examines the roles race, gender, and disability played in the medical sterilization of African American men in Virginia during the opening decade of the twentieth century. Using the experimental work of Dr. Charles Carrington as a window into the negative eugenics movement, it describes how state actors worked to create a barrier between Blackness and white society. Highlighting the cases of Hiram Steele, Frank Baylor and Richard Mills, this article looks closely at how African American men were characterized by medical professionals. Further, it analyzes medical professionals' strategic use of racialized and gendered stereotypes to legitimize their actions. Finally, it places African American men at the forefront of the state's first sterilization program.

What to Read Now: Indigenous Horror

What to Read NowIndigenous Horror Heather Hall (bio) ERIKA T. WURTH White Horse Flatiron Books DEVON A. MIHESUAH The Hatak Witches University of Arizona Press STEPHEN GRAHAM JONES The Only Good Indians Saga Press Click for larger view View full resolution WHAT THE WORLD THINKS it knows about Indigenous peoples of North America could be likened to a Polaroid snapshot taken off the deck of a cruise ship in a foreign land, over which European spectators will forever sigh and wax poetic, exclaiming, "This, then, is an Indian." It is not uncommon for n8v folks dressed in regalia to be asked such guileless questions as Where is your teepee? and Do you still hunt buffalo? We live in a world that uses as the foundation for its caricature of us such Hollywood inventions as Espera Oscar de Corti, an Italian American actor who lied for many years about his heritage while working under his chosen nom de plume, "Iron Eyes Cody." It was inevitable that in the face of such willfully comedic misunderstandings of an entire continent's people that we would, ourselves, begin controlling the narrative through a practice that is foundational to most Indigenous cultural life—storytelling. I have been extraordinarily fortunate to take up my bookselling vocation at a time that is remarkably rich in Indigenous voices across all storytelling genres. I have celebrated each new Indigenous children's book, every volume of poetry—each Indigenous voice is a miracle—but it is Indigenous horror that somehow most delights me. It's hard to imagine a genre more perfectly suited to a people whose resilience has persevered in the face of the horrifically dehumanizing force that is colonization and its concomitant atrocities—from forced removal to forced sterilization and everything in between. [End Page 26] ERIKA T. WURTH White Horse Flatiron Books I had the opportunity to meet Erika T. Wurth at a bookselling conference and was intrigued by the premise of her new novel, White Horse, which centers Chikashsha culture and highlights the contrast of urban and reservation Natives. The Lofa (Sasquatch and Bigfoot's gorier Chikashsha cousin) is featured as the primary villain of this story, though one could argue that the primary horror is intergenerational trauma, with the Lofa as scapegoat. This book follows Kari James, as she retraces her mother's life in an effort to discover why she abandoned her husband and days-old infant. Wurth sprinkles in enough mysticism to mask this horror story as fantasy—until the very end, when the nature of the story is revealed in gut-punching fashion. Wurth tells this story with scenes from Kari's favorite Indian bar, an ongoing obsession with Stephen King, and complex family relationships. It's an utterly enjoyable read and feels both foreign and familiar to me, as an Oklahoma Chikashsha who lives in that space that exists between urban and reservation Native but occupies neither. DEVON A. MIHESUAH The Hatak Witches University of Arizona Press In The Hatak Witches, by Devon A. Mihesuah, we follow detective Monique Blue Hawk through a murder investigation in a story that blends truth and fiction with remarkable aplomb. This story, set in Oklahoma, features a place called the Hollow, whose description closely resembles my grandfather's stories about the Cross Timbers, an ecological region of Oklahoma. His stories painted the Cross Timbers as a terrifying place, so I was delighted to find it in a horror story set in my home state. This story features shapeshifting witches, awesome Oklahoma skies, and the deep, abiding belief that owls are bringers of evil. STEPHEN GRAHAM JONES The Only Good Indians Saga Press Stephen Graham Jones's The Only Good Indians follows a group of Blackfeet youth via a series of increasingly fantastical newspaper headlines and their matching backstories. The first half to two-thirds of this story is more a tale of woe than true horror, but in the moment the genre proves true, the reader is met with the most exquisitely casual depiction of brutality. In this way, Jones aptly elucidates the casual relationship Indigenous people have with resilience in response to violence. This story has a sharp, sometimes dry wit—slipping social...

Victims of eugenic sterilisation in Utah: cohort demographics and estimate of living survivors

Eugenicists at the beginning of the twentieth century feared that the "unfit" were outbreeding the "fit" and promoted interventions like sterilisation as a solution to the perceived problem. Over 60,000 people were sterilised across the United States, victims of eugenic programs implemented in 32 states. Utah had a particularly aggressive eugenic sterilisation program, hailed by eugenicists for sterilising such a large proportion of its population, and lasting well into the 1970s. The goal of the present study was to determine who, at the demographic level, was targeted by this eugenic practice in Utah, and to also estimate how many survivors of the program might still be alive in2023. We used archival records and data abstracted from charts at the Utah State Developmental Center to construct an observational cohort of people sterilised under Utah's coercive, eugenic sterilisation program. We described the demographics of the cohort and presented a life table analysis to estimate the number of survivors still living in2023. At least 830 men, women, and children (modal age of 15-19, 53.6% female) were sterilised in Utah institutions under a program that was launched in 1925, peaked in the 1940s, and concluded in the 1970s. The life table analysis predicts approximately 54 survivors (36 women, 18 men), with an average age of78. Many people sterilised under Utah's eugenics law are likely living today. While some states have taken steps to reckon with their roles in depriving people of their reproductive rights, Utah lacks even an official acknowledgment of this shameful, medical history. Given the advanced age of the potential survivors, time is running out for a reconciliation that can be experienced by those who were most harmed by the practice. This research was supported by three grants from the National Human Genome Research Institute at the U.S. National Institutes of Health (RM1HG009037, R25HG010020, R01HG010567).

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Revisiting psychiatric support for the National Socialist Agenda in Germany: Implications for medical and residency training

The transition of power from a failing Weimer Republic to the National Socialist (Nazi) government was characterized by many economic and politically-motivated changes. Economic crises and the overcrowding of psychiatric hospitals in Germany were the setting for these events. The eugenics movement, although not unique to Germany in the 1920s, would eventually culminate in the compulsory sterilization, euthanasia, and extermination in concentration camps. Historical accounts tend to focus on political and military leaders with the role of medical professionals often overlooked or forgotten. Additionally, there are connections between these programs and medical research. This article aims to elucidate the factors that influenced their role in this historical tragedy and their current implications on how physicians train, learn, and practice role of the medical professionals.

Republicans, Democrats, & Doctors: The Lawmakers Who Wrote Sterilization Laws.

During the 20th Century, thirty-two state legislatures passed laws that sanctioned coercive sexual sterilization as a solution to the purported detrimental increases in the population of "unfit" or "defective" citizens. While both scholarly and popular commentary has attempted to attribute these laws to political parties, or to broad or poorly defined ideological groups such as "progressives," no one has identified the political allegiance of each legislator who introduced a successfully adopted sterilization law, and the governor who signed it. This article remedies that omission.

The Wages of Crying Roe: Some Realism About Dobbs v. Jackson Women’s Health Organization

The U.S. Supreme Court’s reasoning in Dobbs v. Jackson Women’s Health Organization cannot be taken seriously. The Court’s stated ra-tionale for rejecting continued protection of the abortion right—that abortion is not deeply rooted in nineteenth century history and tradi-tion—applies with equal force to other substantive due process rights that the Dobbs Court repeatedly insisted were not under threat even without considering stare decisis, including contraception, sexual inti-macy between consenting adults, and same-sex marriage. One should add inter-racial marriage and protection from involuntary sterilization to that list. Rather than applying its draconian version of the “history and tradition” test in a principled fashion, the Court decided the case based upon moral opposition to abortion and a failure to appreciate that abortion bans old and new are also shaped by gender bias, not just by concerns for fetal life. Further evidence for this realist account of the Court’s decision can be found in the Dobbs Court’s disregard of self-restraint both procedurally and in the opinion-writing process. It is not going too far to charge the Court with having acted lawlessly. A future Court will readily be able to explain why it is overruling Dobbs.