Pregnancy and Public Health Hypocrisy

     

                                Pregnancy and Public Health Hypocrisy

 

By  Dr. Gene Tinelli, MD, PhD.

  

Pregnancy and Public Health Hypocrisy

  

     

      In a sane society, public health policy toward pregnancy aims to maximize

      those  behaviors that enhance maternal and prenatal health and minimize

      those behaviors that  harm maternal and prenatal health. To optimally use

      limited public resources, a rational  policy would use available medical

      research to support the most beneficial behaviors and  target the riskiest

      behaviors. However, we do not have a sane society. Instead, we have  a

      society where almost everything is corrupted by the War on Drugs,

      including our  health policies regarding pregnancy. Currently, these

      policies put both the health of the  mother and the child at risk.

      Criminal Justice Professionals, not Doctors, Set Current Policy

      Until recently, health care professionals set policy toward pregnancy and

      prenatal  development. This was certainly appropriate. Now, however, drug

      warriors and  prohibitionists at the state level, many with little to no

      health care expertise, have taken  over policy. They and only they - not

      mothers, not doctors or other health  professionals - dictate what is and

      what is not appropriate health care. 

      Although the Drug War has gone on for almost a century, pregnant women

      were not  targeted by drug warriors until the 1980s. This was due to the

      rising use of cocaine  during that decade, and to the media’s response to

      a 1985 study(1) that was headed by  Dr. Ira Chasnoff. Dr. Chasnoff’s study

      reported that mothers who use cocaine had  babies with a variety of

      developmental problems, such as low birth weight, small head  size,

      increased rates of prematurity and increased rates of abruptio placenta,

      where the  placenta separates from the wall of the uterus. In addition,

      the study reported that there  were some neuro-behavioral problems, such

      as irritability, difficulty focusing, and some  feeding problems. When it

      was published in The New England Journal of Medicine, the  study created a

      media frenzy about an “epidemic” of crack babies that was going to 

      inundate America. (2) 

      Chasnoff was not alone in finding problems with pregnancies where cocaine

      was used.  Other research has reported problems associated with cocaine

      use during pregnancy,  including increased exposure to sexually

      transmitted diseases, maternal weight loss,  nutritional deficits and

      polydrug use, premature detachment of the placenta, premature  birth and

      reduced/low birth weight, reductions in newborn body length and head 

      circumference, and rare birth defects including genito-urinary tract

      malformations and  extremely rare bone and neural tube abnormalities.

    

     Limited Treatment Facilities

      A sane response to these findings would be to reach out in as many ways as

      possible to  drug-using women, offering them prenatal care and treatment.

      But America had then,  and has now, limited treatment facilities. Of

      these, only a small number take pregnant  women and even fewer offer

      residential treatment for pregnant women with children.  (3)

      Prohibitionists did not respond to the need for such facilities by

      offering more  treatment centers. Instead, a number of states modified

      their civil child protection laws  to mandate that doctors report pregnant

      drug-using mothers to child welfare  authorities. In addition, the

      definition of child neglect was expanded to encompass cases  in which a

      newborn is “physically dependent on” or tests positive for an illegal

      drug. (4)

      Up until recently, no state had enacted a law that specifically

      criminalizes prenatal  conduct. (5) According to the Center for

      Reproductive Law and Policy, prosecutors have used statutes prohibiting

      abuse or neglect of children to charge women for actions  that potentially

      harm the fetus. (6) Some have also argued that pregnant women “delivered”

      drugs to “minor” children — fetuses — through the umbilical cord. (7) In

       addition, a mother’s or newborn’s positive drug test has led to charges

      of assault with a  deadly weapon (cocaine), contributing to the

      delinquency of a minor, and possession of  a controlled substance. (8) In

      cases in which infants tested positive and died soon after  birth, women

      have been charged with homicide or feticide. (9) Some women have even 

      been prosecuted for drinking alcohol (10) or failing to follow a doctor’s

      order to get  bed rest or refrain from sexual intercourse during

      pregnancy. (11)

     

      Over 200 Women Prosecuted

      Estimates based on court documents, news accounts, and data collected by

      attorneys  representing pregnant and parenting women indicate that at

      least 200 women in more  than thirty states have been arrested and

      criminally charged for their alleged drug use or  other actions during

      pregnancy. (12) The majority of women prosecuted have been low- income

      women of color, (13) despite the fact that rates of illegal drug use are

      similar  across race and class lines. (14) According to one analysis,

      “poor Black women have  been selected for punishment as a result of an

      inseparable combination of their gender,  race, and economic status.” (15)

      Often, information indicating possible drug use has  been provided to law

      enforcement officials by medical personnel — possibly in violation  of

      constitutional and statutory guarantees of confidentiality. (16) In many

      of the cases,  women have been pressured into pleading guilty or accepting

      plea bargains, some of  which involve jail time. However, those women who

      have challenged their charges have  succeeded in reversing penalties

      imposed on them for their prenatal conduct. In fact,  every appellate

      panel and most trial courts to rule on the use of existing criminal 

      statutes to punish women for their conduct during pregnancy have found

      that these  prosecutions are without legal basis, or are unconstitutional,

      or both.

      Currently, only some states have modified their civil child protection

      laws to mandate  reporting to child welfare authorities or to define child

      neglect to encompass cases in  which a newborn is “physically dependent

      on” (17) or tests positive for (18) an illegal  drug. A few of these

      states also require reporting of fetal alcohol syndrome or evidence  of

      alcohol use, (19) while only one mandates reporting a positive drug test

      prior to  birth. (20) In some instances, such a report may only trigger an

      evaluation of parenting  ability and the provision of services; in others,

      it may become the basis for temporarily  removing custody of the newborn.

      (21) One state specifically prohibits the use of a lone  positive drug

      test as the basis for a report to child welfare authorities, (22) and

      several  others prohibit basing criminal proceedings solely on a positive

      toxicology. (23) Another  state, recognizing that such reporting raises

      serious issues of doctor-patient  confidentiality, provides reporting to

      the health department for “service coordination,”  but only if the woman

      consents. (24) Still another state provides that, if a woman is  informed,

      health care providers may test new mothers and newborns for alcohol and 

      other drugs, but allows a physician discretion in determining whether

      abuse or neglect  has occurred and reporting is required. (25)

      Nevertheless, hundreds, if not thousands, of women across the country have

      had their  children taken away from them because of a single positive drug

      test. As in the criminal  context, women of color have been particularly

      vulnerable to losing their children, even  though white women use illegal

      drugs at the same rate as women of color. A study by  Dr. Chasnoff,

      conducted in Pinellas County, Florida, found that black women were ten 

      times more likely than white women to be reported to civil authorities if

      an infant was  prenatally exposed to an illegal drug. (26)

      Although pregnant women in other states continue to face attempts to

      civilly commit  them for the purpose of protecting their fetuses from

      potential harm, (27) South  Carolina went further. Though most criminal

      charges filed against women for their  behavior during pregnancy are the

      result of individual prosecutors who pursue a few  cases, in 1989 the city

      of Charleston, South Carolina, established a joint effort among its 

      police department, prosecutor’s office, and the Medical University of

      South Carolina  (MUSC), to punish pregnant women and new mothers who

      tested positive for cocaine.  (28) The policy, which ultimately would set

      a standard for the state, required that  pregnant women seeking

      obstetrical care at MUSC must submit to non-consensual drug  testing. It

      is important to note that MUSC is a state-funded hospital and the only

      medical  facility in the Charleston area to treat indigent and Medicaid

      patients, a majority of  whom are African-American. 

      If a mother went to MUSC to give birth or for prenatal care and tested

      positive for  cocaine, the physicians would be forced to immediately

      report her to the authorities,  and she would be arrested and prosecuted.

      When this policy began, there was no drug treatment available in

      Charleston for pregnant or parenting women. Mothers who  tested positive

      at MUSC were simply jailed, often moments after giving birth. 

      The eventual result of this policy was a 1996 South Carolina Supreme Court

      decision,  Whitner v. State, which allowed a woman to be criminally

      prosecuted for drug use  during her pregnancy. The ruling came in the case

      of Cornelia Whitner, who in 1992  pleaded guilty to child neglect after

      her baby was born with traces of cocaine in its  system. Ms. Whitner was

      sentenced to eight years in prison. 

      “This case is about ensuring newborns a healthy future,” said Margaret

      Crawford, board  chair of The Alliance for South Carolina’s Children.

      “South Carolina’s Attorney General Charles Condon thinks jail will deter

      substance abuse. However, treatment centers are  already reporting that

      far fewer women are seeking treatment and prenatal care due to  this

      policy - causing further harm to women, children and families. ”

      “South Carolina Attorney General Condon’s War on Drugs has turned into a

      war on  pregnant women who need treatment,” said Daniel Abrahamson,

      Director of Legal  Affairs for the Lindesmith Center and one of the

      attorneys representing the broad array  of health organizations in this

      case before the High Court. “Sadly, Attorney General  Condon has ignored

      the countless pleas of physicians and alcohol and drug treatment 

      providers to treat, not prosecute, pregnant women suffering from chemical

      dependence.  Now, the women and children most in need of help are

      suffering horribly as a result of  Mr. Condon’s misguided and Draconian

      policies.”

    

 

      Uniting Against Punitive Policies

      Public health organizations, including the American Medical Association

      and the  American Public Health Association, oppose the prosecution of

      pregnant women who  use drugs. In addition, the Lindesmith Center’s Office

      of Legal Affairs, in conjunction  with nearly two dozen medical and public

      health organizations, has submitted an amicus  (”Friend of the Court”)

      brief to the U.S. Supreme Court in support of plaintiffs in  Ferguson v.

      The City of Charleston. In addition, 10 women, including nine women of 

      color, arrested for testing positive, challenged the policy on various

      constitutional and  statutory grounds and are now asking the United States

      Supreme Court to overturn the Fourth Circuit’s decision to uphold the

      policy. 

      All these groups recognize that South Carolina’s current approach will

      only keep the  women who most need prenatal care from seeking it for fear

      of being imprisoned and  prosecuted and losing their children. In

      addition, this policy harms the mothers by  keeping them from going to a

      doctor for drug treatment. The American Academy of Pediatrics has stated,

      “punitive measures taken toward pregnant women, such as  criminal

      prosecution and incarceration, have no proven benefits for infant health.”

      (29)  In fact, studies indicate that drug-using women who receive prenatal

      care have healthier  children. (30)

     

      Studying the Cocaine Studies

      Before we fill overcrowded prisons with pregnant women and mothers, a look

      at the  research that followed Chasnoff’s initial study is warranted. 

      A meta-analysis of most 1980s studies on prenatal cocaine use found

      serious methodological flaws, such as a lack of control groups, failure

      to distinguish cocaine use  from the use of other drugs, failure to study

      the ensuing health of the newborn, and the  use of case reports alone.

      (31)Presented with children randomly labeled “prenatally  cocaine-exposed”

      and “normal,” childcare professionals ranked the performance of the 

      “prenatally cocaine-exposed” children below that of “normal,” despite the

      actual  performance. (32) But when medical personnel did not know

      beforehand which infants  were exposed to cocaine, they could not detect

      cocaine withdrawal syndrome. (33)  Well-controlled studies found no

      increase in Sudden Infant Death Syndrome. In addition, no causal link

      could be established between cocaine use and poor fetal  development, even

      though cocaine, like many drugs and medicines, enters the  bloodstream of

      the developing fetus and has the potential to affect development. Among 

      the general population, there has been no detectable increase in birth

      defects that may  be associated with cocaine use during pregnancy. (34)

      The problem with making a direct causal link comes from the fact that the

      problems suffered by children exposed to cocaine can stem from many

      factors. For example, many  are born prematurely to mothers who had little

      or no prenatal care and are returned to  a neglectful environment. The

      lack of quality prenatal care is associated with undesirable  effects

      often attributed to cocaine exposure: prematurity, low birth weight and

      fetal or  infant death. (35) But cocaine itself has not been proven to be

      any more damaging than  any other drug used by pregnant women, and

      children with Fetal Alcohol Syndrome are  much more likely than crack or

      cocaine babies to suffer from mental retardation that is  permanent.

      (36-40)

      Research paid for by the National Institute on Drug Abuse and the Albert

      Einstein Medical Center in Philadelphia states that, “Although numerous

      animal experiments and  some human data show potent effects of cocaine on

      the central nervous system, we  were unable to detect any difference in

      performance, verbal or full scale IP [intelligence]  scores between

      cocaine-exposed and control children at age 4 years.” (41)

   

      Alcohol, Tobacco, Do the Most Harm

      Abuse of alcohol, more than any other recreational drug, causes the

      greatest number of  and most severe birth defects: 9.1/1000 or

      approximately 1/100 live births are diagnosed  with Fetal Alcohol Syndrome

      or alcohol-related neuro-developmental disorder, and a  larger number

      experience “fetal alcohol effects.” (42)

      Tobacco use is also strongly associated with low birth weight, prematurity

      and growth  retardation, Sudden Infant Death Syndrome, low cognitive

      achievement, behavioral  problems, and, in some cases, mental retardation.

      Also, urine samples collected from  newborn infants of mothers who smoked

      during pregnancy detected breakdown  products of nitrosaminoketone, a

      known carcinogen and a chemical found only in  tobacco. (43-47)

      Ill Effects of Poverty on Children Can Last a Lifetime

      Nevertheless, the risks of alcohol and tobacco are not what caught the

      media’s  attention. Crack babies caught its attention. Chasnoff painted a

      dark picture behind  society’s morbid embrace of crack babies. “The image

      of the crack baby really moved  out there,” he said. “Politicians really

      picked it up. It worked into the trend of writing about the underclass.

      It’s sexy, it’s interesting, it sells newspapers and it perpetuates the 

      us-versus-them idea.” In fact, said Chasnoff, “Poverty is the worst thing

      that can happen  to a child.” (48)

      Indeed, factors strongly associated with poor fetal development include

      the stressors  and health risks associated with poverty: lead exposure,

      psychiatric problems such as  major depression and depressive symptoms

      associated with life stress, lack of social  support, low weight gain, and

      polydrug use. (49-52)

      These factors also affect children long after they are born, making it

      difficult for them to  succeed in school and increasing the risk that they

      will develop poor relationships with  drugs or develop other

      self-destructive or abusive behaviors. The 6-year-old boy who lived in a

      crack house where he stole a gun and shot a classmate is a tragic case in

      point.

      What do we make of all the research to date? Most of the evidence points

      to the lack of  quality prenatal care and the use of alcohol and tobacco

      as primary factors in poor fetal  development among pregnant cocaine

      users. Of all birth defects, 10-15% are due to environmental agents (53),

      10-15% are hereditary (54), 1- 5% are from chemical  (including drug)

      exposure (55,56) and the rest are due to unknown factors. (57)

      Poor prenatal care often results in premature births, low birth weight,

      and other fetal  development problems, while provision of quality prenatal

      care to heavy cocaine users  (with or without drug treatment) has been

      shown to significantly improve fetal health  and development and reduce

      substance use. (58)

      So what should we do now? If we are truly concerned about maternal and

      fetal health  and we want to follow the War on Drugs mentality and the

      South Carolina court decision, then we should also begin to criminally

      prosecute pregnant women who use  alcohol or smoke nicotine cigarettes. If

      this sounds insane, at least it is not hypocritical.  What is insane is

      that not only are we punishing pregnant women and mothers who are 

      chemically dependent, we are reducing drug treatment for women, thus

      locking poor  women in a cycle of poverty, worsening the most noxious

      factor for their fetuses,  poverty. (59,60) Criminalizing substance abuse

      during pregnancy discourages substance- using or abusing women from

      seeking prenatal care, drug treatment, and other social  services, and

      sometimes leads to unnecessary abortions. (61, 62)

 

      Punishing substance users and abusers during their pregnancies threatens

      the health of  the mothers and children, and seriously compromises women’s

      rights to privacy. It also ignores the serious shortage of drug treatment

      programs for pregnant and parenting  women and fails to address the

      overall lack of access to reproductive health care  services. The author

      of a recent study on the effectiveness of mandatory treatment  concluded,

      “the children of drug-using mothers may be most effectively served by the 

      development of available, efficacious, and welcoming services for women

      and families.”  (63)

      We have created a system that severely punishes those who use certain

      illicit substances that cause mild to moderate harm, virtually ignores

      the use of substances  that cause much greater harm, and encourages the

      creation of a poorer prenatal  environment for those most at risk. This is

      not an optimal public health policy.

      We need to stop this insanity. Our children and our future are at grave

      risk. We need to end the Drug War now. 

    

                         

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    REFERENCES:

 

 

      1. Chasnoff IJ, Bruns, WJ, Schnoll WJ, Burns KA, Cocaine use in pregnancy,

      New England Journal  of Medicine 313: 666-669 (1985)

      2. Greider, Katharine. “Crackpot Ideas.” Mother Jones. July/Aug,, pp 53-56 (1995)

      3. Humphries D.,et al, Mothers and Children, drugs and crack: Reacton to

      maternal drug  dependence, Women and Criminal Justice 199w;1:81-99

      4. Wendy Chavkin et al., Efforts to Reduce Perinatal Mortality, HIV, and

      Drug Addiction: Survey  of the States, 50 JAMWA 164: 164-65 (1995)

      5. The Center for Reproductive Law & Policy, Punishing Women for their

      Behavior During  Pregnancy: An Approach That Undermines Women’s Health and

      Children’s Interests. New  York: Center for Reproductive Law & Policy, 1996

      6. See, e.g., Commonwealth v. Welch, 864 S.W.2d 280 (Ky. 1993) (affirming

      reversal of child  abuse conviction,finding that to construe the child

      abuse statute to apply to a woman’s prenatal  conduct would make the

      statute impermissibly vague and violate legislative intent); Sherriff v 

      Encoe, 885 P.2d 596, 598 (Nev. 1994) (child abuse statute inapplicable to

      woman who used  methamphetamines during pregnancy; to hold otherwise would

      “open the floodgates to  prosecution of pregnant women who ingest such

      things as alcohol, nicotine, and a range of  miscellaneous, otherwise

      legal, toxins”); Commonwealth v Kemp, 75 Westmoreland L.J. 5 (Pa.  Ct.

      C.P. 1992), aff’d, 643 A.2d 705 (Pa. Super. Ct. 1994) (affirming dismissal

      of charges of  recklessly endangering another person or endangering the

      welfare of a child against a pregnant  woman who allegedly ingested

      cocaine while pregnant; finding that neither “child” nor “person”  include

      an unborn “fetus”). 

      7. See, e.g., Johnson v. State, 602 So. 2d 1288 (Fla. 1992) (reversing a

      woman’s convictions for  “delivering drugs to a minor” via the umbilical

      cord); People v Hardy, 469 N.W.2d 50 (Mich. Ct.  App.) (statute

      prohibiting delivery of cocaine to children was not intended to apply to

      pregnant  drug users), leave to appeal denied, 471 N.W.2d 619 (Mich. 1991). 

      8. See, e.g., State v Inzar, Nos. 90CRS6960, 90CRS6961 (N.C. Super. Ct.

      Robeson Cty. Apr. 9,  1991), appeal dismissed, No. 9116SC778 (N.C. Ct.

      App. Aug. 30, 1991) (dismissing charges  against a woman who allegedly

      used “Crack” during her pregnancy under statutes prohibiting  assault with

      a deadly weapon and delivery of a controlled substance because a fetus is

      not a  person within the meaning of the statutes); State v. Alexander, No.

      CF-92-2047, Transcript of  Decision (Okla. Dist. Ct. Tulsa Cty. Aug. 31,

      1992) (dismissing charges of unlawful possession of  a controlled

      substance and unlawful delivery of a controlled substance to a minor

      brought  against a woman who ingested illegal drugs while pregnant,

      finding that the presence of drugs in  defendant’s system does not

      constitute possession and transfer of the drug through the umbilical  cord

      is not “volitional”). 

      9. See People v. Jones, No. 93-5, Reporter’s Transcript (Cal. Juv. Ct.

      Siskiyou Cty. July 28, 1993)  (dismissing homicide charges against woman

      whose newborn died allegedly as a result of  prenatal drug use, finding

      that legislative history did not support application of murder statute to 

      fetus’s death); Jaurigue v Justice Court, No. 18988, Reporter’s Transcript

      (Cal. Super. Ct. San  Benito Cty Aug. 21, 1992) (dismissing fetal homicide

      charges against woman who suffered  stillbirth allegedly as a result of

      her prenatal drug use, finding that neither legislative history nor  the

      statute’s language suggested that a mother could be prosecuted for murder

      for her fetus’s  death), writ denied, (Cal. Ct. App. 1992); State v

      Barnett, No. 02DO4-9308-CF-00611 (Ind.  Super. Ct. Allen Cty. Feb. 11,

      1994) (notice accepting state’s motion to withdraw child abuse  charges

      and dismissing homicide charges brought against woman whose infant tested

      positive for  cocaine and (lied shortly after its premature birth). 

      10. See State v. Pfannenstiel, No. 1-90-8CR (Wyo. Cty. Ct. Albany Cty.

      Jan. 5, 1990) (pregnant  woman charged with child abuse for drinking

      alcohol); Joan Little, Woman Jailed After Baby Is  Born Intoxicated, St.

      Louis Post-Dispatch, Nov. 26, 1991, at 3A (woman was charged with 

      second-degree assault and child endangerment after her son was allegedly

      born with signs of  fetal alcohol syndrome). 

      11. See People v. Stewart, No. M508197, Reporter’s Transcript, at 4 (Cal.

      Mun. Ct. San Diego  Cty. Feb. 26, 1987) (pregnant woman charged under a

      criminal child support statute for failing  to follow doctor’s advice to

      get bed rest, to abstain from sexual intercourse, and to seek  prompt

      medical attention when she experienced bleeding). 

      12. Lynn M. Paltrow, Criminal Prosecutions Against Pregnant Women:

      National Update and  Overview (1992): The Center for Reproductive Law and

      Policy, In the Courts: Decisions  Involving Penalties Imposed Against

      Women for Their Conduct During Pregnancy (Feb. 1996). 

      13. Gina Kolata, Bias Seen Against Pregnant Addicts, N.Y Times, July 20,

      1990, at A13. 

      14. As a survey by the Southern Regional Project on Infant Mortality concluded:

        Newspaper reports in the 1980s sensationalized the use of crack cocaine

        and  created a new picture of the typical female addict: young, poor,

        black, urban, on welfare, the  mother of many children, and addicted to

        crack. In interviewing nearly 200 women for this  study, a very

        different picture of the typical chemically dependent woman emerges. She

        is  most likely white, divorced or never married, age 31, a high school

        graduate, on public  assistance, the mother of two or three children,

        and addicted to alcohol and one other  drug. It is clear from the women

        we interviewed that substance abuse among women is not  a problem

        confined to those who are poor, black, or urban, but crosses racial,

        class,  economic and geographic boundaries. — Shelly Gehshan, Southern

        Regional Project on Infant  Mortality, A Step Toward Recovery 1 (1993). 

       15. Dorothy E. Roberts, Punishing Drug Addicts Who Have Babies: Women of

      Color, Equality,  And the Right of Privacy, 104 Harv. L. Rev. 1419, 1424  (1991). 

      16. One federal law provides that, except under limited circumstances,

      “[r]ecords of the  identity, diagnosis, prognosis, or treatment of any

      patient … maintained in connection with the  performance of any program

      or activity relating to substance abuse education, prevention,  training,

      treatment, rehabilitation, or research, which is conducted, regulated, or

      directly or  indirectly assisted by any department or agency of the United

      States shall … be confidential …”  42 U.S.C. 290dd-2 (1995). See also

      Legal Action Center, Confidentiality: A Guide to the Federal  Laws and

      Regulations (1991); Legal Action Center, Dispelling the Myth: Legal Issues

      of  Treatment Programs Serving Pregnant Addicts (1994).

      17. See, e.g, Fla. Stat. ch. 415.503 (1995); Mass. Ann. Laws ch. 119, 51A

      (Law. Co- op. 1995);  Okla. Stat. tit. 63, 1-550.3(A) (1995); Utah Code

      Ann. 62A-4a-404 (1995). 

      18. See, eg, Ill. Comp. Stat. Ann. ch. 325, para. 5/3 (1995); Ind. Code

      31-6-4-3.1 (a) (1) (B)  (1995); Iowa Code 232.77(2) (1995); Minn. Star.

      626.5562(2) (1995). A survey of state  maternal/child health and drug

      treatment agency directors found that other states may, as a  matter of

      policy, require reporting to child protective authorities of pregnant

      women or infants  with positive toxicology results, and/or define a

      positive result as evidence of child neglect or  abuse. Wendy Chavkin et

      al., Efforts to Reduce Perinatal Mortality, HIV, and Drug Addiction: 

      Survey of the States, 50 JAMWA 164: 164-65 (1995). 

      19. See, eg., Ind. Code 31-6-4-3.1 (a) (1) (1995); Utah Code Ann.

      62A-4a-404 (1995). 

      20. See Minn. Stat. 626.5662(2) (1995). 

      21. See Bonnie Baird Wilford & Jacqueline Morgan, Intergovernmental Health

      Policy Project,  Families at Risk: Analysis of State Initiatives to Aid

      Drug-Exposed Infants and Their Families 34- 47 (1993). 

      22. See Cal. Penal Code 11165.13 (Deering 1995). 

      23. See, eg., Iowa Code 232.77(2) (1995); Ky. Rev. Stat. Ann. 214.160(5) (Michie 1995). 

      24. See Kan. Stat. Ann. 65-1,163 (1994). 

      25. See Ky. Rev. Stat. Ann 214.160 (Michie 1995). 

      26. Ira J. Chasnoff et al., The Prevalence of Illicit-Drug or Alcohol Use

      During Pregnancy and  Discrepancies in Mandatory Reporting in Pinellas

      County, Florida, 322 New Eng. L Med. 1202:  1204 (1990).

      27. Wendy Chavkin, Mandatory Treatment for Drug Use During Pregnancy, JAMA

      266: 1556  (1991)

      28. Philip H. Jos, et al., The Charleston Policy on Cocaine Use During

      Pregnancy: A Cautionary  Tale, 23 J.L. Med. & Ethics 120 (1995). See also

      Plaintiffs’ Memorandum in Support of their  Partial Cross-Motion for

      Summary Judgment and in Opposition to Defendants’ Motion for  Summary

      Judgment, Ferguson v City of Charleston, No. 2:93-2624-2 (D.S.C. filed Oct. 5, 1993).

      29. American Academy of Pediatrics, Committee on Substance Abuse,

      Drug-Exposed Infants,  Pediatrics 86: 639-641 (1990).

      30. Andrew Racine et al., The Association Between Prenatal Care and Birth

      Weight Among  Women Exposed to Cocaine in New York City, JAMA 270: 1581 (1993).

      31. Lutiger B, Grahan K, Einarson TR, Koren G. Relationship between

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