Call for Measures to Ensure Health, Human Rights and Public Health Protections for Detained Immigrant Women

Mr. Thomas P. Giles
Acting Director
U.S. Immigration and Customs Enforcement
Atlanta Field Office
180 Ted Turner Dr. SW, Suite 522
Atlanta, GA 30303
thomas.p.giles@ice.dhs.gov

Mr. Tae D. Johnson
Acting Director
U.S. Immigration and Customs Enforcement
Washington Office
500 12th St SW
Washington, DC 20536

Mr. Monty Wilkinson
Acting U.S. Attorney General
U.S Department of Justice
950 Pennsylvanie Avenue, NW
Washington, DC 20530-0001

Mr. Joseph V. Cuffari
Inspector General
Office of the Inspector General
Mail Stop # 0305
U.S. Department of Homeland Security
245 Murray Lane, SW
Washington, DC 20528-0305

Ms. Katherine Culliton-González
Officer for Civil Rights & Civil Liberties
Mail Stop #0190
U.S. Department of Homeland Security
2707 Martin Luther King, Jr. Avenue, SE
Washington, DC 20528-0190
crcl@dhs.gov

Mr. John D. Trasviña
Principal Legal Advisor
U.S. Immigration and Customs Enforcement
Office of the Principal Legal Advisor
500 12th Street, SW, Mailstop 5900
Washington, DC 20536

Mr. David Paulk
Warden
Irwin County Detention Center
132 Cotton Drive
Ocilla, GA 31774

Re:      Call for Measures to Ensure Health, Human Rights and Public Health Protections for Detained Immigrant Women

Dear Secretary Mayorkas, Mr. Giles, Mr. Johson, Mr. Wilkinson, Mr. Cuffari, Ms. Culliton-González, Mr. Trasviña and Mr. Paulk:

The New York City Bar Association writes with deep concern about a whistleblower complaint and documented reports of medical abuses of detained immigrant women in the Irwin County Detention Center (Irwin), and broader patterns of medical neglect and failures to protect the health of detained immigrant women in the United States, especially in view of the significant threat to the public’s health posed by the COVID-19 pandemic. These troubling practices occurred in a detention system characterized by weak and uneven oversight, and raise serious concerns about violations of human rights and basic human dignity, as well as related constitutional concerns, as discussed more fully below.

The Department of Homeland Security (DHS) has launched an internal investigation, which must be bolstered by independent medical evaluations and continued scrutiny by Members of Congress and advocates. Several members of Congress wrote to the UN High Commissioner for Human Rights to request an independent investigation, alleging a pattern of abuse and neglect in ICE detention centers that calls for an international response.[1] While such investigations take place, the rights of the affected women must be protected.  We call for their deportations to be halted. It must be emphasized that this medical abuse, which is alleged to have affected at least 43 women, is merely a particularly egregious example of the dehumanizing effects of the current immigration detention system. It is imperative that overall accountability for abuses and neglect not be limited to investigation into these discrete events. As an interim measure,  DHS must take appropriate actions to ensure the provision of adequate medical and mental health services, as well as public health protections, to all women held in immigration detention by the U.S. government.

As the City Bar noted in its December 2015 letter to the Obama Administration, “[D]etention raises particularly severe concerns for vulnerable individuals,” and “is neither effective nor justified as a deterrent to the migration of families and individuals into the United States.”[2] We recently called upon the Biden Administration to take all steps to ensure that the detention of immigrants returns to be the exception, and not the rule, and to ban entirely the use of detention for immigrant children and families.[3]  Here we address, in particular, the needs and rights of immigrant women who have experienced reproductive violence while in detention.[4] In addition, in accordance with the City Bar’s view that due process and international human rights standards require a “strong presumption against the detention of asylum-seekers and immigrants,”[5] we call for an end to the wholesale civil detention of asylum-seekers and immigrants in the United States.  We also call for significant enhancement of the safeguards and oversight protections necessary to ensure the health and safety of detainees, including the reproductive rights of immigrant women, as underscored by the disturbing events laid bare in the whistleblower’s complaint.

I. BACKGROUND INFORMATION

A whistleblower complaint dated September 14, 2020, alleged that, over a period of time while awaiting immigration hearings or deportation, detained immigrant women at Irwin were subjected to nonconsensual and medically aggressive and unnecessary gynecological procedures.[6] According to the findings of an independent review team, the women were subjected to unnecessary surgery without adequate disclosure of risks and alternatives to procedures, and were pressured to undergo procedures inconsistent with the standard of care. The procedures allegedly took place without informed consent. The independent medical review team confirmed the abuse by analyzing records of 19 women.[7] The team plans to review additional medical records as they become available. Some of the women underwent gynecological surgeries that were coerced, nonconsensual, and unnecessary. At least 43 women have alleged nonconsensual or unnecessary gynecological procedures, and some sources assert that the number is at least 57.[8]

Some of the women have been deported, making it more difficult to collect testimonies and evidence. Since investigations began, others have been slated for deportation. The deportations of potential witnesses by DHS may constitute interference with the investigation, possible obstruction of justice, and destruction of evidence, all of which are criminal acts. Members of Congress have called on Immigration and Customs Enforcement (ICE) to halt the deportations, which are in violation of long-standing ICE policy not to deport witnesses of open investigations, and condemned ICE’s continuing efforts to “stonewall” Congressional inquiries.[9] Under the  circumstances presented here, it further appears likely that the women are eligible to receive U visas,[10] a protected humanitarian status for cooperating victims of qualifying criminal acts, which would provide them with status to remain in the United States and eventually adjust to lawful permanent residents. While the new Administration has announced a temporary moratorium on removals and a change in enforcement priorities, the moratorium has already been challenged in federal court.[11] In addition, ICE’s previous actions, already contrary to their own guidance, raise serious concerns regarding compliance with such executive actions.

The abuses suffered by the women at Irwin, while outrageous, are not aberrations. They must be contextualized within long-standing abuses against detained immigrants and the history of gynecological abuse, sterilization, and anti-immigrant practices.[12] Given the nature of the violations, it is critical that they be immediately and thoroughly investigated, that the victims be afforded opportunities for redress, and that the responsible parties engage in a plan to rectify and guarantee non-repetition

II. DETENTION FACILITY STANDARDS AND OVERSIGHT

Although the previous administration introduced harsh new anti-immigrant policies, structural issues in immigration detention have also contributed to the current crisis. A significant challenge in holding ICE accountable for quality of care within its detention centers is the diverse types of facilities and the contracts and standards governing the facilities. Immigrants are detained in many different facilities, including various Service Processing Centers (SPCs) owned by ICE and typically operated by contract detention staff, Contract Detention Facilities (CDFs) owned and operated by private prison companies, local and county jails under Non-Dedicated Intergovernmental Service Agreements (IGSAs) with ICE, local facilities that only house ICE detainees under Dedicated Intergovernmental Service Agreements (DIGSAs), and facilities operated by the United States Marshals Service under Marshals Service Intergovernmental Agreement (IGAs).[13] There are no statutes or regulations that set binding standards for the operation of these facilities.[14] Since ICE was established in 2000, ICE facilities have operated under a set of National Detention Standards (NDS). New outcomes-based sets of standards, the Performance-Based National Detention Standards (PBNDS) 2008 and PBNDS 2011, were subsequently established (and revisions were made to the 2011 standards in 2016).[15] However, these standards are not consistently applied across facilities, resulting in a system where some facilities are governed by older versions of the standards, others are not covered at all,[16] or in some cases, it is unclear from a contract which standards apply.[17]

Adding to this complex web of regulations are the separate sets of standards applicable to ICE Family Residential Centers,[18] to Customs and Border Protection detention (which, given that CBP is not supposed to hold individuals for longer than 72 hours, has much less comprehensive medical care standards)[19] and to the supervision of unaccompanied children under the Office of Refugee Resettlement, which is under the Department of Health and Human Services rather than DHS.[20]

Irwin is failing to meet the standards under which it is currently governed. It is a facility owned and operated by LaSalle Correctional Corporation, under an IGSA contract and governed by the 2016 PBNDS.[21] The 2016 PBNDS state that facilities must provide (either directly or through contracted services) “medically necessary and appropriate” medical care, including “specialty health care.”[22] Medical services must be provided by “appropriately trained and qualified personnel, whose duties are governed by thorough and detailed job descriptions and who are licensed, certified, credentialed and/or registered in compliance with applicable state and federal requirements.”[23]

The PBNDS standards on language interpretation, consent, and women’s health care are particularly relevant to the detained immigrant women at Irwin. In order to provide “meaningful access” for those with limited English proficiency (LEP), facilities must provide interpretation and translation through either bilingual staff or professional services.[24] The PBNDS’ detailed guidance on communicating with LEP detainees requires that all written materials detainees receive be translated into Spanish, and, to the extent practicable, into other languages spoken by significant numbers of detainees. If written materials are not available in the detainee’s language or for illiterate detainees, oral interpretation or assistance must be provided.[25] Additionally, new detainees “shall be informed orally or in a manner in which the detainee understands about how to access, appeal or communicate concerns about health services.”[26] Previous internal investigations of detention facilities have revealed failures to provide interpretation services during medical examinations and to provide medical consent forms in Spanish or explain English-language forms.[27]

The 2016 PBNDS required that staff make “reasonable efforts to ensure that detainees understand their medical condition and care.”[28] Additionally, the healthcare provider must “obtain informed consent in advance of any non-emergency examination or treatment.[29] In addition to standard consent practices, “separate documented informed consent is required for invasive procedures” such as surgeries.[30]

The standards also specifically address women’s health care, requiring that “[f]emale detainees shall receive routine, age appropriate gynecological and obstetrical health care, consistent with recognized community and clinical guidelines for women’s health services.”[31] To meet optimum levels of compliance with the PBNDS, a facility’s “provision of gynecological and obstetrical health care shall be in compliance with standards set by the National Commission on Correctional Health Care (NCCHC).”[32]

The sparse policies put in place to protect migrants’ basic health and safety human rights are insufficient, and compounding that is a lack of policy implementation that makes violation of detained immigrant women’s healthcare rights almost inevitable. As localized failures like the current Irwin crisis demonstrate, detained immigrant women are particularly vulnerable to medical abuses that have enduring physical as well as psychological impact.[33] ICE does not have adequate procedures to ensure their policies are implemented in the over two hundred facilities where immigrants are detained. Of these facilities, ICE owns only five, contracting for the use of approximately two hundred.[34] This makes enforcement difficult, if not impossible. Additionally, many ICE contracts with private contractors do not have expiration dates, resulting in the absence of opportunities to make renewal contingent upon improvements.[35]

Finally, ICE’s inspection procedures are failing to resolve problems in facilities. While executive department agency policy requires that “Government retains inherently governmental decision-making authority” in service contracts,[36] ICE does not retain governmental decision-making control of the health and medical policies and practices of the facilities where it contracts for immigrant detention. The oversight systems they have in place do not create sustained compliance.[37] Inspections of ICE facilities are conducted by offices within ICE, including the Enforcement and Removal Operations (ERO) division, the Office of Detention Oversight, and those offices’ contractors, rather than by independent investigators.[38] The Office of the Inspector General, in its review of the inspections process (including of the Irwin facility specifically) has found that these inspections are not governed by clear procedures, are too infrequent, lack follow-up, and therefore are not successful in ensuring compliance with standards or improvements in conditions.[39] Within facilities where ICE has contracted to use beds for detention, ICE does not use contractual tools available to enforce its policies with subcontractors, leading to a further dilution of the protection for detainees.[40] In all, there is a lack of accountability which jeopardizes the health and safety of ICE-detained immigrant women.

III. INTERNATIONAL HUMAN RIGHTS STANDARDS

The United States has obligations under international law to respect human rights, and those obligations are implicated by the allegations of the whistleblower’s complaint. Indeed, the United States played an essential role in the drafting of the Universal Declaration of Human Rights (UDHR)[41], in which Member States pledged to achieve “the promotion of universal respect for and observance of human rights and fundamental freedoms.”[42] Ensuring respect for these basic principles is essential to maintaining the United States’s stature and influence in promoting human rights around the world.[43] Particularly relevant are the United States’ commitments as a party to the International Covenant on Civil and Political Rights (ICCPR), the Convention Against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment (CAT), and the Protocol Relating to the Status of Refugees.

The ICCPR, signed and ratified by the United States, recognizes “the inherent dignity and of the equal and inalienable rights of all members of the human family.”[44] The United States has also ratified the CAT, which bans the intentional infliction of severe physical or mental pain or suffering, either by state actors or with the acquiescence of state actors.[45] The reported abuses outlined in the whistleblower complaint likely fall under the CAT’s definition of torture[46] and can lead to long term psychological sequelae and disorders.[47] The United States did not ratify the 1951 Refugee Convention, but has ratified the subsequent 1967 Refugee Protocol, which incorporates the rights of the Convention and establishes standards for the humane and dignified treatment of refugees, but removes the geographical and time-based restrictions on the Convention.[48]

While the United States has not ratified all the key human rights treaties, the failure to do so does not mean that the United States is free to ignore or violate those treaties. Pursuant to the Vienna Convention on the Law of Treaties between States and International Organizations or between International Organizations,[49] a state “is obliged to refrain from acts which would defeat the object and purpose of a treaty” when it has signed but not yet ratified a treaty.[50] Its “object and purpose is understood to mean the ‘essential goals’ of a treaty… a signatory state need not comply with every part of a treaty, but it must comply with the most important parts.”[51] The conduct at Irwin violates the object and purpose of several treaties that the United States has signed but not ratified, such as the International Covenant on Economic, Social and Cultural Rights (ICESCR) and the Convention on the Elimination of all Forms of Discrimination Against Women (CEDAW).[52] Under the ICESCR,[53] states must ensure “the right of access to health facilities, goods and services on a non-discriminatory basis, especially for vulnerable or marginalized groups” and “equitable distribution of all health facilities, goods and services.”[54] The Committee on Economic, Social and Cultural Rights asserted that states must ensure that migrants have equal access to “preventive, curative, and palliative health services, regardless of their legal status and documentation.”[55] And, the objective of CEDAW is “the elimination of all forms of discrimination against women on the basis of sex.”[56]

These international treaties and guidelines should not be disregarded and must inform U.S. laws and regulations governing ICE detention centers and the treatment of immigrants and refugees. The reported abuses of immigrant women in ICE detention centers reflect a larger pattern of degrading treatment of migrants in the United States – in violation of international standards – and of policies designed to disincentivize and punish migration.[57]

 IV. CONSTITUTIONAL PROTECTIONS:  THROUGH A HEALTH AND PUBLIC HEALTH LENS

The U.S. Constitution protects citizens and noncitizens alike from violations of rights fundamental to our nation’s concepts of liberty. The Fourteenth Amendment has been invoked to protect bodily autonomy and safeguards against state-compelled medical invasions absent compelling reasons.[58] Gynecological procedures performed for no medical purpose, as reported at Irwin, violate the constitutional rights of the detained women on whom the procedures were performed. There is no legitimate state purpose that would justify, or even  provide a rational basis for, the actions alleged in the whistleblower complaint. Moreover, rather than isolated incidents, they are properly seen as indicative of a larger system of discrimination against immigrants, and more specifically immigrant women. The absence of sufficient policies to prevent medical abuse and neglect, as well as the lack of implementation procedures which may have allowed the abuse to be carried out, raise distinct constitutional issues.

A. Punitive Conditions and Harm

Immigration detainment is not the result of a criminal justice process although detention constitutes immigration enforcement.[59] The significant number of asylum seekers who are detained merely for their undocumented status (not for having committed a crime unrelated to entering the U.S.) undermines U.S. and international asylum policy, which is intended to permit people to seek asylum based on risk of persecution in their home country. While improper entry is a criminal violation (a federal misdemeanor) and a civil one, ICE’s role is to oversee civil detentions of those awaiting immigration hearings or removal.

The prohibition against inflicting punishment in the civil detention context applies to everyone regardless of immigration status,[60] acts as a check on plenary power, and must apply to those detained as they are living an incarcerated life.[61] Ignoring the medical needs of detained immigrant women violates the prohibition on cruel and unusual punishment;[62] it follows that inflicting painful, unnecessary medical treatment also is cruel and unusual. Inflicting unwanted medical care on those incarcerated is impermissible without an overriding legitimate government purpose.[63]

In Youngberg v. Romeo, the Supreme Court held that substantive due process protects the rights of those in civil confinement, finding that mentally challenged individuals in state-run institutions must be free of unnecessary infringements on their liberty. In doing so, the Court’s decision impacted the future of civil confinement, applying minimum standards and requiring that individuals in civil detention receive “more constitutional protection, more considerate treatment, and conditions of confinement…”[64] than those in criminal confinement. Specifically, the Youngberg court evaluated the infringement of constitutionally protected liberty after the plaintiff was unduly restrained.

In Hamm v. DeKalb, the Court held that the Eighth Amendment applies to confinement only in a criminal context and after a “formal adjudication of guilt” because the State would not have the power to punish in pretrial imprisonment. “This court holds that in regard to providing pretrial detainees with such basic necessities as food, living space, and medical care the minimum standard allowed by the due process clause is the same as that allowed by the eighth amendment for convicted persons. The Court recognizes that the limitations imposed by the eighth amendment and the due process clause arise in different contexts. Nonetheless, with respect to the provision of basic necessities to individuals in the state’s custody, the two provisions necessarily yield the same result.”[65] The Constitution requires minimum standards to be upheld and imposes on courts to protect the rights of prisoners.[66]

To determine whether there is a substantive due process violation in this context, courts apply the deliberative indifference standard.[67] In Hamm, the Court applied the standard to both the pretrial detention pursuant to the Fourteenth Amendment’s protection of substantive due process and the imprisonment (post-conviction), pursuant to the Eighth Amendment.[68] The substantive due process violation arises from conditions that would violate the Eighth Amendment prohibition against cruel and unusual punishment.

In Bell v. Wolfish, the Court created a test to determine whether an action is “punishment” as the Constitution prohibits punishment of those not convicted. The Court held that when an act lacks legitimate government purpose, a court can infer the action is punishment and violates the Constitution.[69] Taken together, Estelle v. Gamble, Hamm v. DeKalb, Youngberg v. Romeo[70] and Bell establish that the failure to meet medical needs of a detained person violates substantive due process. In the case of the detained immigrant women at Irwin, there was more than medical neglect; the allegations demonstrate care that was medically unwarranted, non-consensual, abusive, and unsafe. The medical team analyzing the records concluded the procedures were not medically warranted or performed for the patients’ own good.[71]  Based on the above, the actions alleged in the whistleblower complaint amount to punishment and occurred with deliberate indifference and without a legitimate government purpose.

B. Reproductive Rights and Privacy

Of particular relevance here, the Fourteenth Amendment’s guarantee of substantive due process protects a range of intimate decisions people make, including decisions about what medical care they will accept or refuse, or decisions about procreation and pregnancy.[72] Due process underlies the right to privacy in reproductive decisions.[73] Even before Griswold v. Connecticut, which marks the start of the modern reproductive rights jurisprudence, “procreation” was considered a fundamental right.[74] Nonconsensual gynecological procedures inflicted on women held in the ICE detention center not only violated their right to be free from compelled medical procedures, but also, in some cases the procedures affected future fertility, thereby violating their right to make decisions about pregnancy and procreation in the future. There was no compelling government purpose for the procedures; in fact, an independent reviewer found that the procedures were not medically warranted.[75]

The alleged bodily intrusions against those held in ICE detention facilities were not for legitimate medical purposes, public health,[76] or the medical good of the patients. In fact, it appears that one purpose of the reported non-consensual gynecological procedures may have been a fraudulent money-making scheme, which calls for further investigation.[77]

C. Consent and Informed Refusal

The right of competent adults to refuse healthcare interventions even when they are life- sustaining is also well established.[78] Nonconsensual gynecological touching, intrusion, and assault or battery are each a fundamental abridgement of a person’s rights – a threat to dignity and within the proper scope of substantive due process. Jacobson[79] and later Cruzan,[80] citing the Jacobson decision, established the “right to refuse” which governs refusal by informed adults of any and all medical procedures. Absent incapacity or incompetence, adults make their own medical decisions. As Justice Cardozo famously declared, “Every human being of adult years and sound mind has a right to determine what shall be done with his own body…”[81]

Informed consent has two distinct features: disclosure to the patient, and the patient’s appreciation and acceptance of the intervention and its risks. The consent must be voluntary, free from coercion, and made after receipt and understanding of the relevant information.[82] Informing these requirements is a right to bodily integrity. As described by the Supreme Court nearly 130 years ago:

No right is held more sacred, or is more carefully guarded by the common law, than the right of every individual to the possession and control of his own person, free from all restraint or interference of others, unless by clear and unquestionable authority of law.[83]

For informed consent to be effective, a patient with capacity, or their surrogate decision maker if the patient lacks capacity, must receive information about the condition, the nature of the proposed treatment, potential benefits, potential risks, and available alternatives (including forgoing treatment).[84] The right to informed consent “can be effectively exercised only if the patient possesses enough information to enable an intelligent choice.” [85] Furthermore, the disclosure must be made in a manner that is accessible to the patient given their language needs and understanding. Safeguards include delivering information in the patient’s native language.[86] Practitioners must also receive training to meet the needs of the cultures they serve,[87] an essential element when dealing with vulnerable populations such as refugees.

The reportedly unwanted gynecological examinations, treatments, surgeries, and other medically aggressive and medically unnecessary procedures call for an analysis of both informed consent and informed refusal. Had the patients had the proper and correct information, and the entirety of the relevant information about the procedures, the risks, and the long-term consequences, it is reasonable to believe they would not have consented. According to the independent reviewer the women allegedly were not given the chance to hear or digest the complexity of the medical information.[88] For instance, had the women understood that some cysts are normal monthly occurrences, that some medicines (in some instances, apparently wrongfully given) caused abdominal pain, and that their conditions likely did not require any special medical care and were not dire, one can reasonably assume that they would have refused the procedures.[89] And, the evidence suggests that they were not in need of drastic medical intervention.[90]

Informed refusal to undergo a recommended procedure tends to be challenged more than informed consent to undergo a recommended procedure because refusals challenge medical advice as opposed to agreeing with it. In fact, doctors occasionally seek out competency testing when recommended medical care is refused.[91] This leads to circular arguments in which the refusal of care by otherwise rational patients is itself interpreted as evidence of their lack of competence to make medical decisions, creating even further pressure on the patient to accept the treatment.[92] “Practitioners must be guarded against stigmatizing patients who decline their treatment recommendations by characterizing them as lacking intelligence or mental competency.”[93] Indeed, plaintiffs in the Irwin case alleged that the patients’ status as ICE detained immigrant women made them vulnerable, which increased the likelihood that the doctor’s power and professional decisions would carry more weight.[94] This may have led to the underlying presumption that had the women refused, their competence, intelligence, and ability to decide for themselves would be attacked. As demonstrated in the allegations at issue here, there is no evidence of voluntariness, a prerequisite to informed consent.[95]

Informed consent and informed refusal must be voluntary. Detained immigrant women rarely feel their actions are voluntary. They live under the threat of punishment and under the power of others making decisions for them.[96] Detained women here from other countries may be unaware of their constitutional rights and may not ask relevant questions or make an effort to absorb information. After signing any consent, the patients may have felt that they rightly transferred control to the doctor.[97]

V. CALL FOR ACTION

In light of the above evidence and the serious legal, ethical and human rights issues raised by a review of the publicly available evidence, the New York City Bar Association calls upon your offices to cooperate with investigations of the reports by immigrant women while detained at Irwin of medical abuses and human rights violations, as well as violations of constitutional rights. It is of utmost importance that the scope of any investigation must include a review of the role and contribution of for-profit management companies in the medical abuses that have been reported, as well as the systemic patterns of medical neglect and lack of oversight. Additionally, for those immigrant women who have made reports and are survivors of Dr. Amin’s abuse, and may also be witnesses in criminal investigations, their deportations must be halted. In efforts to mitigate the suffering of all immigrant women who remain detained at Irwin or other detention centers and reduce risks to their health and wellbeing, especially during the pandemic, we also call for increased oversight of detention centers and monitoring of compliance with applicable detention center standards, an overall improvement in the standard of medical care for detained immigrant women, and appropriate actions to protect the health of detained immigrant women from the serious threat posed by COVID-19 in accordance with applicable agency and public health guidance.

Finally, we call for an end to the wholesale detention of immigrants in the United States.  The action we call for is not intended to bar the confinement of particular individuals if warranted in connection with criminal charges unrelated to entering the U.S. – who will otherwise be entitled to due process protections – but as a remedy for the well-documented systemic failures of U.S. immigration policy in ensuring the rights of all detained immigrants, including all those detained in congregate facility settings, as protected under United States and international law.

Respectfully,

Immigration & Nationality Law Committee
Danny Alicea, Chair
Mary Beth Morrissey*

Bioethical Issues Committee
Alan Brudner, Chair
Anne Houck Zimmerman*

Health Law Committee
Brian T. McGovern, Co-Chair
Heather Hatcher, Co-Chair

International Human Rights Committee
Lauren Melkus, Chair

Sex & Law Committee
Farah Diaz-Tello, Co-Chair
Iliana Konidaris, Co-Chair

*Primary Drafters