public health advocacy began coming to light. Georgia As recent as September 2020, whistleblower complaints were filed concerning "the rate at which hysterectomies are performed on immigrant women under ICE (U.S. Immigration and Customs Enforcement) custody at ICDC". The whistleblower complaint also includes reports from many detained women who described "not understanding why they had received a hysterectomy" and even details "miscommunications" that led to patients receiving hysterectomies they may not have needed. Related court cases Buck v. Bell (1927) Carrie Buck was raped by a nephew of her adopted parents in Virginia at the age of 17. In an attempt to cover up the assault, her family committed her to the Lynchburg State Colony for Epileptics and Feebleminded. Soon later, the colony realized that Buck was pregnant with her assailant's child. At the colony, Dr. Albert Sidney Priddy examined Buck and deemed her to be unfit due to her feeblemindedness. Priddy recommended her for sterilization. This was brought to the courts in order to sanctify the sterilization order. Buck's biological mother was labeled as feebleminded, so Buck was used as "proof" that feeblemindedness was hereditary and sterilization was necessary for the common good. The Supreme Court voted 8-1 stating that being feebleminded led to promiscuity and sterilization was justified. Buck was then sterilized under the Virginia 1924 compulsory sterilization statue. The Supreme Court case of Buck v. Bell confirmed the constitutionality of sterilization of the feebleminded and "unfit". This case solidified that involuntary sterilization was not cruel or unusual punishment and it did not violate due process, but rather it helped the good of the country as a whole. Individual rights of reproduction were now able to be taken for the public good. Cases of involuntary sterilization rose significantly after this case in 1927. Madrigal v. Quilligan (1978) In the 1970s a group of Chicana women brought up a federal class action lawsuit against a hospital in Los Angeles County regarding their sterilizations. Women in the class were allegedly given false information regarding sterilization. The titular plaintiff, Dolores Madrigal, a Latina woman, was allegedly told several times by a medical professional that sterilization could be reversed. Other women involved in the case signed consent forms for their sterilizations because they were allegedly sedated or manipulated by doctors and medical staff. A common reason for forcing the sterilizations of these women was apparently the burden that their future children would