1. Skinner v. Oklahoma (1942)
1.1. Facts
1.1.1. Parties
1.1.1.1. Jack Skinner (Plaintiff)
1.1.1.2. State of Oklahoma (Defendant)
1.1.2. What happened
1.1.2.1. Oklahoma passed statute in 1935, "Habitual Criminal Sterilization Act", a person who has been convicted two or more times for felonious crimes can be rendered sexually sterile.
1.1.2.1.1. Skinner was 1st convicted in 1926 for stealing chickens
1.1.2.1.2. Skinner was convicted for a second time in 1929 of robbery with fire arms
1.1.2.1.3. Skinner was convicted for a 3rd time in 1934 again for robbery with firearms.
1.1.3. Procedural History
1.1.3.1. Attorney General of Okhlahoma instituted proceedings against Skinner in 1936 per the "Habitual Criminal Sterilization Act"
1.1.3.1.1. Skinner challenged the Act as unconstitutional by reason of the fourteenth Amendment.
1.1.3.2. Supreme Court of the U.S. reversed ruling
1.2. Issue before the Court
1.2.1. Did the Habitual Criminal Sterilization Act violate the 14th amendment? Was this Act discriminatory between similar offences of larceny and embezzlement since they had different penalties.
1.3. Rule of Law
1.3.1. States are required to apply equal protection under the 14th amendment
1.3.1.1. Fifth amendment ensures the right to be free from multiple prosecutions or punishments for a single crime and also have personal liberties protected by Due Process of Law
1.4. Application/Analysis
1.4.1. How does the Criminal Sterilization Act of Oklahoma violate the 14th Amendment?
1.4.1.1. The law was not being applied consistently for similar offences that were classified under "prohibitory laws, revenue acts, embezzlement, or political offenses"
1.4.2. How did the State of Oklahoma's Sterilization Act violate the offenders right to due process
1.4.2.1. The state of Oklahoma would violate the offenders right to due process as the law was not being applied for similar offenses
1.4.2.1.1. Additionally, depriving the right to bear offspring may potentially have consequences by affecting the personal liberties of the offender.
1.4.3. No evidence has been provided to determine sterilizing the offender committing a felony/larceny as compared to an offender committing embezzlement can be passed on to offspring
1.5. Conclusion
1.5.1. The United States Supreme Court reversed the decision stating that the Sterilization Act violates the 14th Amendment which grants equal protection to all citizens.
1.6. The impact of the decision
1.6.1. Gerbert v. Hickman (2001)
1.6.1.1. The complaint presents a claim for alleged violation of Gerberts substantive due process rights which denied him the fundamental right to procreate in violation of the fourteenth Amendment guarantee of substantive due process. The US Court of Appeals Reversed, vacated and remanded judgement for prisoner who alleged warden violated his constitutional right to procreate by refusing to allow him to artificially inseminate his wife.
1.6.2. U.S. v. Miller (2009)
1.6.2.1. Relationship to equal protection are guaranteed by the Due Process and Equal Protection Clauses. The US District Court denied Defendant's motion to dismiss indictment for being a felon in possession of a firearm.
1.7. Why a healthcare professional would care about the decision and how it has changed the way health care operates?
1.7.1. A Healthcare professional would care about the decision because it affects the way a practitioner practices healthcare, generally using evidence based practices. In this case of eugenics where similar offenses bore different punishments to the extent of depriving offspring, would have dire consequences for future generations.
1.7.1.1. Additionally, this methodology of practicing without any evidence would set a negative precedent for healthcare.
1.8. At least two current health care practices that have been influenced by the holding
1.8.1. Had the US Supreme Court decided else, countless offenders would have burdened an already burdened healthcare system by the sterilization process.
1.8.2. Patients that may have needed much needed medical treatment may have had to wait longer due to shortages of practitioners available to see them without the sterilization affected patients.