In the Matter of Edith M.M. Hayes

93 Wash. 2d 228, 608 P.2d 635 (1980)

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In the Matter of Edith M.M. Hayes

Washington Supreme Court
93 Wash. 2d 228, 608 P.2d 635 (1980)

  • Written by Nicole Gray , JD

Facts

Edith Melissa Maria Hayes was born mentally retarded due to a birth defect, which limited her cognitive development but not her physical development. At 16 years old, Edith had the cognitive abilities, at best, of a five-year-old but was sexually active. Edith’s mother, Sharon Hayes, and Edith’s doctors believed that Edith was at risk of becoming pregnant, although she did not understand her reproductive system and lacked the ability to exercise independent judgment in relationships with males. After a year of seeking education and alternative contraception methods, Ms. Hayes petitioned a state superior court for appointment of guardianship over Edith’s person and for authority to have Edith sterilized. To support her petition, Ms. Hayes included medical testimony from Edith’s doctor and a report from the medical-health board. However, Ms. Hayes did not provide any evidence regarding Edith’s ability to gain capacity to give informed consent to be sterilized or to care for a child, nor was there evidence of alternatives to sterilization. The superior court denied Ms. Hayes’s petition on summary judgment, finding that it was not authorized to order sterilization. Ms. Hayes appealed.

Rule of Law

Issue

Holding and Reasoning (Horowitz, J.)

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