birth control

Birth Control Safe and effective options.

n.

1. Voluntary limitation or control of the number of children conceived, especially by planned use of contraceptive techniques.
2. A contraceptive technique.

Methods of fertility control, including contraception, that are intended to prevent pregnancy, and means of interrupting early pregnancy. The efficacy of the various methods and consistency of use vary widely. Factors associated with degree of effectiveness include user age, income, marital status, and intention (that is, whether contraception is used to delay or to prevent pregnancy). The available methods consist of hormonal methods (including oral contraceptives, subdermal implants, and injectable formulations), sterilization, intrauterine devices, barrier and chemical methods, and fertility awareness methods.

Oral contraceptives contain one or both of two compounds (estrogen and progestin) similar to the hormones that regulate the menstrual cycle. Each monthly series of pills either suppresses ovulation or alters the uterine lining and the cervical mucus, or both. See also Estrogen; Menstruation; Progesterone.

Postcoital contraception is another hormonal method. In emergency situations (for example, rape) high dosages of oral contraception can be used. One dose is given within 72 h after the episode of unprotected intercourse, and an additional dose is given 12 h later.

The subdermal implant consists of small hollow rods that are placed under the skin of a woman's upper arm and release a low, continuous dose of a progestin. It is more effective than the oral contraceptives and, because it lacks estrogens, does not pose a risk of cardiovascular complications. It is reversible, lasts for 5 years, is nearly as reliable as sterilization, and is less expensive than birth control pills.

An injection of progestin suppresses ovulation and can be given every 3 months. It can be used by women who should not take estrogens. Women experience irregular bleeding in the first 6 months of use, often followed by cessation of menses with continuing use. It has been shown to be as safe and reliable as sterilization, yet is readily reversible.

The main mode of action for the intrauterine device (IUD) is considered to be prevention of fertilization. Of the two commercially available IUDs in the United States, the one containing copper is designed to remain in place for 10 years; for users over the age of 25, the pregnancy rate is less than 1%. The other one releases a daily dosage of the natural hormone progesterone to suppress the uterine lining and requires annual replacement.

Barrier methods include the male condom, female intravaginal pouch, diaphragm, cervical cap, vaginal contraceptive sponge, and various chemical preparations. The condom is a sheath of thin latex (sometimes coated with spermicide) or animal tissue that covers the penis. The intravaginal pouch, also known as a female condom, is a loose-fitting vaginal liner with an external rim designed to hold it in place. The diaphragm is a shallow rubber cup with a ring rim that fits securely in the vagina to cover the cervix. The cervical cap is a smaller, thimble-shaped latex device that fits over the cervix. The diaphragm and cervical cap are used with spermicides. The vaginal contraceptive sponge is a soft, synthetic, disposable sponge that fits over the cervix and, when moistened, continuously releases spermicide.

Fertility awareness methods enable a woman to estimate when she is fertile so that she can practice abstinence or use a barrier method during those times. Techniques used to determine fertility include cervical mucus observation, and body signs with temperature tracking. Such methods are often less effective for contraception.

Sterilization is the most commonly used method of birth control for women and men both in the United States and worldwide. The procedures do not adversely affect the production of male or female hormones, so that individual sexual characteristics such as sex drive and menses usually remain unchanged. Vasectomy is a minor male surgical procedure that occludes the vas deferens by various means (such as by cautery or suture). In the United States, tubal sterilization in the female is an operation commonly performed through the laparoscope. The instrument that performs the tubal occlusion may be either attached to the laparoscope or inserted through the lower abdomen. See also Pregnancy.

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n

Oral contraceptives, usually a mixture of a steroid having progestational activity and an estrogen.

Techniques to limit family size including contraception, sterilization, and abortion. Some governments do not support birth control, thinking that population is a resource, and birth control is banned by many religious groups. See anti-natalist, natalist.

For more information on birth control, visit Britannica.com.

The duty to produce offspring is frequently referred to as the first commandment in the Bible, as Adam was commanded to "be fruitful and multiply" (Gen. 1:28). The use of any measure to prevent conception is problematic from the standpoint of Jewish law, as it involves abstaining from a biblical duty. Furthermore, some methods of birth control result in explicitly prohibited acts. The proscription of anatomical methods of sterilization such as vasectomy and tubal ligation is derived from Leviticus. 22:24. Methods which interfere with a proper seminal emission, such as coitus interruptus, are condemned as "acts of Er and Onan."

In line with this halakhic attitude toward birth control, elective contraception is not permitted. However, the permissible use of some forms of birth control in various mitigating circumstances is discussed at length in the Talmud and Responsa literature. Legitimate reasons for contraception usually involve the medical welfare of the woman or of the potential fetus in question. The Talmud discusses three categories of women who may (or must, according to some authorities) use a contraceptive device: a minor below the age of 12 (who was allowed to marry at that time), a pregnant woman, and a nursing mother (Ket. 39a).

There are many differences of opinion on the subject of contraception among the later rabbis. When contraception is permitted, the rabbis tend to approve methods which least interfere with the natural sex act. Contraceptives used by women (e.g., diaphragm, IUD) are preferred to the male contraceptive (condom), since the sages rule that women are exempt from the commandment to "be fruitful and multiply." Oral contraceptives are in principle the most acceptable, as they do not interfere artificially with the movement of the sperm, although caution must be exercised lest they upset the menstrual cycle.

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Birth control techniques appear to have been widely available long before the 19th cent. Herbal mixtures were advocated to reduce the sex drive or induce abortion. Contemporaries also Seem to have been aware of the withdrawal technique since at least the early 18th cent., when the practice of coitus interruptus was linked by quack literature to an awesome list of debilitating medical complaints. Male contraceptives were advertised by the early 18th cent., when such ‘armour’, made of animal gut, was used to avoid contracting venereal infections. The 1820s and 1830s saw the first open discussion of birth control techniques. More public debate followed the creation of the so-called Malthusian League (1877-1927), which distributed some 3 million pamphlets advocating birth control.

Before the third quarter of the 19th cent., however, there is little statistical evidence that English couples were practising much family limitation. Birth control before 1870 was restricted to higher social classes and some groups of industrial workers. All this changed after 1870 when, within a few generations, Britain underwent the so-called fertility transition. Between 1880 and 1930 the fertility of women of child-bearing age declined by over 60 per cent and the average size of British families fell by almost two-thirds. This declining birth rate was due largely to the adoption of birth control within marriage. It is also clear that the contraceptive techniques used in the early stages of this decline were largely traditional methods such as abstinence, coitus interruptus, and ‘safe periods’ rather than mechanical aids such as condoms, caps, or sponges. The adoption of birth control within marriage may have been due to a new decision by women to limit the size of their families, prompted by the impact of feminist arguments, growing information regarding the dangers of repeated childbirth, and the impact of universal compulsory schooling in 1880, which reduced the contribution children might make to the household economy.

The term "birth control" was coined by Margaret Sanger in 1921, when she founded the American Birth Control League (later Planned Parenthood). She believed that women should have control over their own bodies and their own pregnancies. Though she recognized birth control in larger social and political contexts and was criticized for working too closely with the eugenics movement, she saw it clearly as a health issue for women. Sanger worked as a nurse in New York City's "Hell's Kitchen" and saw women's health suffering as the result of many pregnancies. Her own mother died of tuberculosis after bearing eleven children.

Sanger had promoted the use of birth control in the decade before 1921 as a means to less restrictive sexuality for women. But such claims were considered far too radical and would not facilitate legalizing contraceptives. Contraceptives had become illegal in the United States in 1873 in a Victorian purity crusade led by Anthony Comstock. For centuries, couples had used a variety of methods of birth control—animal skin condoms, vaginal sponges, douches, abstinence, abortion—but nineteenth-century technology brought rubber condoms into mass production and the mass market. The Comstock laws prohibited all contraceptives and contraceptive information, categorizing them as obscenity. The movement to make them legal again would gain momentum with the aid of the American Medical Association, which promoted birth control as a public health issue.

More permissive attitudes toward sexual behavior developed in the twentieth century—flappers of the 1920s flaunted apparent promiscuity, and by the 1940s the automobile allowed for more privacy in dating, and vending machines were dispensing condoms. Still, numbers of un-married women having sexual intercourse remained comparatively low until the 1960s. Contraceptives were generally intended for, and used by, married couples. The sexual revolution and the introduction of the birth control pill in the 1960s would change that. The United States Supreme Court ruled against a Connecticut law prohibiting the dispensing of contraceptives to married couples in Griswold v. Connecticut (1965), a move that paralleled changing attitudes toward birth control in American society. The women's movement embraced reproductive rights as fundamental to progress for women in the workplace, education, and politics, as they could more easily limit their family size.

The birth control pill was promoted as liberating for women as it did not interfere in the act of sexual inter-course, and it was nearly 100 percent effective. In turn, it was embraced by men, as women became less inhibited in sex because the fear of pregnancy was removed. Other forms of contraceptives such as intrauterine devices and Norplant were marketed in subsequent decades, and while each involved risks, women readily accepted them.

Bibliography

Gordon, Linda. The Moral Property of Women: A History of Birth Control Politics in America. 3rd ed. Chicago: University of Illinois Press, 2002.

Tone, Andrea. Devices and Desires: A History of Contraceptives in America. New York: Hill and Wang, 2001.

—Kathleen A. Tobin

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Control or regulation of conception and birth, either to limit population growth, to increase births among particular populations, or to enable conception through medical intervention.

The terms birth control and family planning (in the sense of limiting births) and the concept of population reduction are controversial in the Middle East. Population, its growth, reduction, and control are at the heart of some of the region's most volatile political conflicts, such as the Arab - Israel conflict and the civil war in Lebanon, a country founded on the notion of proportional power-sharing between Christians and Muslims. Issues related to birth control and contraception also serve as lightning rods for some of the sharper social, cultural, and ideological controversies in the contemporary Middle East, particularly those centering on secular versus religious modes of organization and frames of meaning, women's rights, and the tension between individual and collective rights. In attempting to alter, influence, or control the literal and figurative reproduction of the family as the region's basic social institution and moral structure, birth-control policies straddle political, moral, and religious fault lines, highlighting contending sources of authority and revealing ongoing challenges of national integration and identity in the region.

Advocated by the state and international organizations, birth-reduction campaigns usually target impoverished, powerless, and marginalized groups, thus drawing attention to long-standing socioeconomic inequalities and class-based tensions in major cities such as Cairo, Tehran, and Istanbul. But birth control is not only imposed from above or beyond the contemporary Middle East - it is also chosen in increasing numbers by those living in the region as part of a larger trend toward claiming rights, taking control of personal health and the body, and domestic decision making and financial planning for families' futures. As a facet of projects designed to ensure women's increasing agency in and control over their own lives, birth control has drawn the attention and earned the censure of conservative religious authorities, be they Christian, Muslim, or Jewish.

Manipulating Population Growth

Population growth results from increased birth rates and falling mortality rates, as well as migration. In the major cities of the Middle East, rapid urbanization and dramatic population increases have been a common feature of the last sixty years. Most countries in the region have just attained, or soon will attain, the demographic transition - the stage at which birth rates slow down to replacement levels, death rates having dropped earlier. Rapid population increases in the Middle East have affected patterns of urbanization, labor, and immigration, and have often strained the provision of education, health, and social services in resource-poor countries. For many, state-sponsored policies encouraging birth control symbolize interference in family matters and the negation of such traditional values as the importance of marriage and family. Women's control over their own bodies and their own fertility, afforded by birth control, conflicts with some communities' values concerning the importance of women's chastity, their role in the home, and their status as mothers and nurturers. Others view contraceptive technology as an important tool in areas ranging from national development policy to a woman's safeguarding of her health.

Although the region shares a common culture and a dominant religion (Islam), variations of geography and resource allocation have generated different policy responses to population growth. Whereas some countries seek to limit their populations, others seek to increase theirs. Egypt, Iran, Turkey, Tunisia, Lebanon, and Morocco, lacking a sufficient resource base to support their growing and largely young populations, have supported national family-planning programs designed to reduce population growth. Saudi Arabia, Kuwait, Libya, Iraq, and the Gulf oil states, on the other hand, lack sufficient populations to supply their labor needs and have had pronatalist (probirth) policies. Israel also has a pronatalist policy for its Jewish population, and actively encourages Jewish women to have many children. This policy, however, does not extend to Israel's Arab citizens, who, representing 20 percent of Israel's population, have a higher birth rate and a younger median age than do Israeli Jews. Assisted conception and infertility treatments in Israel are the most advanced in the region, and state subsidies render these services affordable for all Israeli citizens, Arabs and Jews alike.

Overall, the rapid growth of population in the Middle East is a matter of concern within as well as beyond the region. In 1993 the population of the Middle East was approximately 360 million; by 2025 it is expected to reach 700 million. The region's population is young: 41 percent are under 15 years of age. Fears that resources, particularly water, may not stretch to support populations have prompted many governments to make contraceptive use an integral part of their public-health programs and to mount campaigns to encourage the use of family-planning techniques and mechanisms. Yet, women's fertility rates are often influenced more by educational levels and employment than by access to birth-control pills, intrauterine devices, or condoms. Women's status and life possibilities greatly shape their reproductive behavior; women who complete high school and college tend to marry later, and thus give birth to fewer children. Trends toward later marriage in most countries of the region (with the exception of the Occupied Palestinian territories, Yemen, and Oman) should translate into lower birth rates in the coming decades.

Demographic evidence suggests that disease, poverty, and warfare combined to keep population figures relatively even and stable until the beginning of the twentieth century. The population of the central Middle East (excluding North Africa) is estimated to have been around 40 million at the beginning of the twentieth century. By 1950 it had doubled to 80 million (1993, 265 million; 1999, 380 million). Explosive growth followed the end of World War II, when greater emphasis upon public sanitation and healthcare reduced the death rate while the birth rate remained high. In the early 1960s Gamal Abdel Nasser of Egypt and Habib Bourguiba of Tunisia were the first national leaders to appreciate the potentially negative relationship between unrestricted population growth and socioeconomic development, and they feared that the resulting pressure could spur political unrest. The family-planning programs they initiated encountered opposition, but since about 1970 their programs, along with those of Lebanon, Turkey, Morocco, and Iran, have achieved limited success.

Cultural, Political, and Religious Opposition to Family Planning

Opposition has come from political, military, religious, and cultural quarters. Both the culture of the Middle East and the religions of the area - Islam, Christianity, and Judaism - encourage marriage and family. The term birth control (tahdid al-nasl) is considered highly perjorative because it connotes preventing the birth of children. Less objectionable terms are tanzim al-usra and takhtit al-aʾila (family planning), which connote organization and ordering rather than the outright limitation of progeny. Nations of the Middle East have historically sought to augment their strength against enemies by increasing their numbers. To many, birth control is suspect and assumed to be another facet of Western imperialism in disguise; family-planning programs are often considered Western impositions designed to weaken the Middle East.

Political parties and nationalist groups throughout the Middle East affirm that having children constitutes a national duty in order to supply a large population base for military endeavors. Following heavy military losses at the end of the Iran - Iraq War in 1988, both Iran and Iraq emphasized pronatalist policies. Competition among Middle Eastern nations for regional prominence has led them to discourage family planning and advocate high birth rates. National, ethnic, or religious factionalism often translates into lack of support for family planning as each group seeks to enlarge its numbers. European Community governments decided in the 1990s to attack root problems of immigration from the Middle East by initiating programs supporting family planning in North Africa.

Most of the major religious traditions of the area hold that contraception is permitted. Christians are divided on its permissibility. The traditions of Judaism differ, but largely consider it permissible. Islamic jurisprudence condemns a pre-Islamic form of birth control, waʿd (exposure of female infants), but, reasoning from hadith texts, Islam does permit contraceptive use as analogous to coitus interruptus (azl). This is a personal, mutual decision of the husband and wife. Muslim opponents of contraception see it as murdering a potential creation of God and as a denial of the will (irada) and sustaining power (rizq) of God. Furthermore, Islam acknowledges the importance of and the right to sexual fulfillment for both men and women, and thus does not teach that reproduction is the sole or primary justification for marital intercourse.

The continuing importance of family in the Middle East has proved to be the largest obstacle to family planning. Because the status of both spouses, particularly the wife, depends upon the birth of children, family-planning programs have had difficulty encouraging both men and women to consider contraceptive use. One important support has been the Qurʾan's injunction to nurse children for two years, and most women appreciate the risks of becoming pregnant while nursing. The spacing of children as an important contributor to a mother's health is becoming better understood. Children have traditionally been seen as providing economic support for the family and, in the absence of social-security programs, are considered guarantors of parents' financial security in their old age. Finally, children are loved and valued as a true blessing and a gift from God in all the faith traditions and cultures of the region.

Contraception

The most common methods of contraception used by women in the Middle East are birth-control pills and intrauterine devices (IUDs). Concern over sexually transmitted diseases and AIDS has led to increased use and availability of condoms. Much interest has been shown in injectable or implantable contraceptives. Nonreversible sterilization for men or women is prohibited by Islam. Tubal ligations, however, are increasingly common, and because new medical technology makes the procedure reversible, they can be considered religiously permissible. Abortion is frowned upon but permitted in particular situations, mostly those in which the mother's life is threatened. The majority of states ban abortion except when the health of the mother is endangered, at which point responsibility devolves onto the woman's doctor. Tunisia permits abortion.

Family planning and contraception in the Middle East was the subject of worldwide attention and debate at the 1994 International Conference on Population and Development (ICPD) in Cairo. That gathering, as well as the other United Nations conferences held in the 1990s - the 1995 Beijing Conference, the 1999 five-year review of the ICPD (ICPD+5), and the 2000 five-year review of the Beijing Conference (Beijing+5) - witnessed an alliance of conservative Catholic and Muslim religious authorities joining forces to oppose and restrict Middle Eastern women's right to control their own bodies and sexuality.

Bibliography

Ali, Kamram Asdar. Planning the Family in Egypt: New Bodies,New Selves. Austin: University of Texas Press, 2002.

Badran, Margot. Feminists, Islam, and Nation: Gender and theMaking of Modern Egypt. Princeton, NJ: Princeton University Press, 1995.

Bayes, Jane H., and Tohidi, Nayrereh. "Introduction." In Globalization, Gender, and Religion: The Politics of Women's Rights in Catholic and Muslim Contexts, edited by Jane H. Bayes and Nayereh Tohidi. New York: Palgrave, 2001.

Ethelston, Sally. "Water and Women: The Middle East in Demographic Transition." Middle East Report 213 (Winter 1999): 6 - 10.

Inhorn, Marcia. Infertility and Patriarchy: The Cultural Politics ofGender and Family Life in Egypt. Philadelphia: University of Pennsylvania Press, 2002.

Inhorn, Marcia. Quest for Conception: Gender, Infertility, andEgyptian Medical Traditions. Philadelphia: University of Pennsylvania Press, 2002.

Kahn, Susan Martha. Reproducing Jews: A Cultural Account ofAssisted Conception in Israel. Durham, NC: Duke University Press, 2000.

Kanaaneh, Rhoda A. Birthing the Nation: Strategies of Palestinian Women in Israel. Berkeley: University of California Press, 2002.

Musallam, Basim. Sex and Society in Islam. Cambridge, U.K.: Cambridge University Press, 1983.

Omran, Abdel-Rahim. "The Middle East Population Puzzle." Population Bulletin 48, no. 1 (July 1993): 1 - 40.

Omran, Abdel-Rahim. Population Problems and Prospects in the Arab World. New York: United Nations Fund for Population Activities, 1984.

Weeks, John R. "The Demography of Islamic Nations." Population Bulletin 43, no. 4 (December 1988): 1 - 54.

— DONNA LEE BOWEN UPDATED BY LAURIE KING-IRANI

This entry contains information applicable to United States law only.

A measure or measures undertaken to prevent conception.

In the 1800s, temperance unions and anti-vice societies headed efforts to prohibit birth control in the United States. Anthony Comstock, the secretary of the Society for the Suppression of Vice, advocated a highly influential law passed by Congress in 1873. It was titled the Act for the Suppression of Trade in, and Circulation of Obscene Literature and Articles of Immoral Use, but known popularly as the Comstock Act (18 U.S.C.A. § 1416-62 [1964]; 19 U.S.C.A. § 1305 [1964]). The Comstock Act prohibited the use of the mail system to transmit obscene materials or articles addressing or for use in the prevention of conception, including information on birth control methods or birth control devices as well as birth control devices themselves.

Soon after the federal government passed the Comstock Act, over half the states passed similar laws. All but two of the rest of the states already had laws banning the sale, distribution, or advertising of contraceptives. Connecticut had a law that prohibited even the use of contraceptives; it was passed with little or no consideration for its enforceability.

Despite popular opposition, birth control had its advocates, including Margaret Sanger. In 1916, Sanger opened the first birth control clinic in the United States, in New York City. For doing so, she and her sister Ethel Byrne, who worked with her, were prosecuted under the state's version of the Comstock law (People v. Byrne, 99 Misc. 1, 163 N.Y.S. 682 [1917]; People v. Sanger, 179 A.D. 939, 166 N.Y.S. 1107 [1917]). Both were convicted and sentenced to thirty days in a workhouse.

After serving her sentence, Sanger continued to attack the Comstock Act. She established the National Committee for Federal Legislation for Birth Control, headquartered in Washington, D.C., and proposed the "doctor's bill." This bill advocated change in the government's policy toward birth control, by citing the numerous instances in which women had died owing to illegal abortions and unwanted pregnancies. The bill was defeated, due, in part, to opposition from the Catholic Church and other religious groups.

But when the issue of Sanger's sending birth control devices through the mail to a doctor was pressed in United States v. One Package, 13 F. Supp. 334 (S.D.N.Y. 1936), the court ruled that the Comstock Act was not concerned with preventing distribution of items that might save the life or promote the well-being of a doctor's patients. Sanger had sought to challenge the Comstock Act by breaking it and sending contraception in the mail. Her efforts were victorious and the exception was made. The doctor to whom Sanger had sent the device was granted its possession.

Sanger furthered her role in reforming attitudes toward birth control by founding the Planned Parenthood Federation of America in 1942. Planned Parenthood merged previously existing birth control federations and promoted a range of birth control options. In the 1950s, Sanger went on to support the work of Dr. Gregory Pincus, whose research eventually produced the revolutionary birth control pill.

By the 1960s, partly as a result of Sanger's efforts, popular and legal attitudes toward birth control began to change. The case of Griswold v. Connecticut, 381 U.S. 479, 85 S. Ct. 1678, 14 L. Ed. 2d 510 (1965), loosened the restrictions of the Comstock Act. When the Planned Parenthood League of Connecticut opened in 1961, its executive director, Estelle Griswold, faced charges of violating Connecticut's ban on the use of contraceptives (Conn. Gen. Stat. Ann. §§ 53-32, 54-196 [1958]).

A divided Supreme Court overturned Griswold's conviction with a groundbreaking opinion that established a constitutional right to marital privacy. The Court threw out the underlying Connecticut statute, which prohibited both using contraception, and assisting or counseling others in its use. The majority opinion, authored by Justice William O. Douglas, looked briefly at a series of prior cases in which the Court had found rights not specifically enumerated in the Constitution — for example, the right of freedom of association, which the Court has said is protected by the First Amendment, even though that phrase is not used there (for example, NAACP v. Alabama, 357 U.S. 449, 78 S. Ct. 1163, 2 L. Ed. 2d 1488 [1958]). Douglas concluded that various guarantees contained in the Bill of Rights' Amendments One, Three, Four, Five, Nine, and Fourteen, taken together, create "zones of privacy," which include a right of marital privacy. The Connecticut statute, which could allow police officers to search a marital bedroom for evidence of contraception, was held unconstitutional; the government did not have a right to make such intrusions into the marital relationship.

The other branches of the government followed the Court's lead. President Lyndon B. Johnson endorsed public funding for family planning services in 1966, and the federal government began to subsidize birth control services for low-income families. In 1970 President Richard M. Nixon signed the Family Planning Services and Population Research Act (42 U.S.C.A. § 201 et seq.). This act supported activities related to population research and family planning.

More and more, the Comstock Act came to be seen as part of a former era, until, in 1971, the essential components of it were repealed. But this repeal was not necessarily followed by all the states. In the 1972 case of Eisenstad v. Baird, 405 U.S. 438, 92 S. Ct. 1029, 31 L. Ed. 2d 349, the Court struck down a Massachusetts law still on the books that allowed distribution of contraceptives to married couples only. The Court held that the Massachusetts law denied single persons equal protection, in violation of the Fourteenth Amendment.

In the 1977 case of Carey v. Population Services International, 431 U.S. 678, 97 S. Ct. 2010, 52 L. Ed. 2d 675, the Supreme Court continued to expand constitutional protections in the area of birth control. The Court imposed a strict standard of review for a New York law that it labeled "defective." The law had prohibited anyone but physicians from distributing contraceptives to minors under sixteen years of age. The law had also prohibited anyone but licensed pharmacists from distributing contraceptives to persons over sixteen. Carey allowed makers of contraceptives more freedom to distribute and sell them to teens.

Although these early decisions of the Supreme Court opened up the sale and distribution of birth control to the general public, they did not address the issue of school distribution of condoms to high school students. In an effort to decrease the spread of AIDS among New York City's teenagers, the New York Board of Education, in February 1991, directed high schools to make condoms available to students who requested them. AIDS awareness classes were also required. Some of the students' parents objected. They claimed that the availability of condoms violated the New York Public Health Law, section 2504; condom distribution, the parents said, constituted a health service to minor children without parental consent. Parents also argued that condom distribution violated their free exercise of religion.

On December 30, 1993, New York's Supreme Court, Appellate Division, issued a ruling in favor of the parents, prohibiting distribution of condoms to unemancipated minor students without prior consent. The court held that the condom distribution program lacked statutory or common-law authority, and that it violated the parents' due process rights under the Fourteenth Amendment and the New York Constitution (Alfonso v. Fernandez, 195 A.D.2d 46, 606 N.Y.S.2d 259, 88 Ed. Law Rep. 747).

Similar cases were brought throughout the United States. The school boards of San Francisco, Seattle, and Los Angeles all disagreed with the New York court, and authorized the distribution of condoms to students. As a general rule, however, court decisions established that although parents have no control over public school curriculum, they may reserve the right to withdraw their children from classes on birth control and AIDS prevention.

See: Druggist; Family Law; Griswold v. Connecticut; Marriage; Parent and Child; Privacy; Reproduction; Schools and School Districts.

The practice of preventing conception to limit the number of births. (See contraception, family planning, population control, and Margaret Sanger.)

Quotes:

"The blind conviction that we have to do something about other people's reproductive behavior, and that we may have to do it whether they like it or not, derives from the assumption that the world belongs to us, who have so expertly depleted its resources, rather than to them, who have not." - Germaine Greer

"If we can get that realistic feminine morality working for us, if we can trust ourselves and so let women think and feel that an unwanted child or an oversize family is wrong -- not ethically wrong, not against the rules, but morally wrong, all wrong, wrong like a thalidomide birth, wrong like taking a wrong step that will break your neck -- if we can get feminine and human morality out from under the yoke of a dead ethic, then maybe we'll begin to get somewhere on the road that leads to survival." - Ursula K. Le Guin

"It is now quite lawful for a Catholic woman to avoid pregnancy by a resort to mathematics, though she is still forbidden to resort to physics and chemistry." - H. L. Mencken

"Contraceptives should be used on all conceivable occasions." - Spike Milligan

"No woman can call herself free who does not own and control her body. No woman can call herself free until she can choose consciously whether she will or will not be a mother." - Margaret Sanger

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