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Walker v. Pierce
United States Court of Appeals for the Fourth Circuit
560 F.2d 609 (1977)
Dr. Clovis Pierce (defendant) was an obstetrician who worked at a county hospital. Pierce had a policy of asking anyone who was financially unable to care for themselves to agree to be sterilized after the birth of a third child. If the person did not agree, Pierce asked the person to seek care from a different doctor. Virgil Walker (plaintiff) was a Black female with a seventh-grade education. Walker was separated from her husband, receiving Medicaid and other public benefits, and pregnant with her fourth child when she sought care from Pierce. Pierce told Walker about his sterilization policy during their first two visits together. Even though Walker claimed that Pierce threatened to have her public benefits taken away if she refused to consent to sterilization, she did not agree to sterilization during either visit. After Walker’s efforts to obtain a different doctor were unsuccessful, she returned to Pierce for care and signed a sterilization-consent form. Later, Dr. Billy Burke was covering for Pierce and delivered Walker’s baby. Burke spoke to Walker about sterilization. Walker told Burke that she did not want more children and that she consented to permanent sterilization. Walker signed two additional consent forms before the sterilization surgery was finally performed by Pierce. Walker later claimed that she felt it would have been futile to resist the sterilization requests. Walker’s medical bills were paid by Medicaid, with whom Pierce did not have any contractual relationship. Walker and another Black, female patient sued Pierce, claiming that he had unlawfully discriminated against them on the basis of their race, number of children, and Medicaid status. A jury entered verdicts in favor of Pierce. Walker appealed.
Rule of Law
Holding and Reasoning (Bryan, J.)
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