Reproductive Wrongful Convictions: The Making of "Unfit" Mothers

This Article draws a straight line from wrongful convictions of women in the past to criminal charges based on pregnancy and parenting behaviors today. Faulty forensic evidence and biased evidence relying on sex-based stereotypes have, in combination, been used to convict innocent women, particularly in situations where an accident or health event was misconstrued to be a criminal act. Seventy-four percent of exonerated women were convicted when no crime occurred. Similarly, in criminalizing pregnancy behaviors, police, medical personnel, or prosecutors erroneously label a noncriminal event, such as a miscarriage or stillbirth, as criminal. Criminal charges are being brought against new mothers who test positive for their own legally prescribed medicine—for morphine that was given to them by the hospital for pain during labor—or for a controlled substance when the child is born healthy and unharmed.

This Article conceptualizes “reproductive wrongful convictions,” and exposes how marginalized women are being labeled as “unfit” and becoming particularly vulnerable to these charges. Historically and today, the “unfit” label applies to women with disabilities as well as women from racially and economically subordinated communities. Through interviews with women wrongly convicted of harming their children, this Article includes the experiential knowledge of participants in the medical and legal systems, relying on different epistemic backgrounds to conceptualize transforming the law. In addition, the Supreme Court’s recent case, Andrew v. White, demands a greater reckoning of the due process violation that occurs when courts admit character evidence that overwhelmingly relies on sex-based stereotypes and justifies incarceration of the defendant, whether she has committed the charged offense or not.

About the Author

Robert H. McKinney Professor of Law, Indiana University Maurer School of Law. My sincere gratitude to the organizers and participants of the 2025 West Coast Gender, Sexuality, and the Law Conference, the 2024 Decarceration Law Profs Works in Progress, the 2024 American Bar Association Criminal Justice Section Academics (AALS Criminal Justice Roundtables), the 2025 Association of American Law Schools’ Annual Meeting panel on “Pregnancy Crimes,” the Workshop on Regulating Family, Sex, and Gender at the University of Chicago Law School, and the Tulane Law School faculty for the opportunity to present and benefit from feedback on this Article. In particular, I am deeply grateful to Jennifer Oliva, Mary Anne Case, Sarah Gottlieb, Catherine Hancock, Alexis Hoag-Fordjour, Jasmine Harris, Jancy Hoeff el, Laila Hlass, Rachel Kincaid, Carla Laroche, Chris Lau, Rachel López, Cortney Lollar, Jamelia Morgan, Elizabeth Pendo, Angelo Petrigh, Robyn Powell, Maybell Romero, Maneka Sinha, Karen Thompson, and students at the University of Chicago Workshop on Regulating Family, Sex, and Gender for feedback that enriched and grounded this Article. For feedback and insights that made the draft of this Article its strongest, thank you to Shirin Bakhshay, Nila Bala, Sarah Lorr, Megan Stevenson, and Lisa Washington. Finally, thank you to the authors of the thoughtful symposium pieces published in the UCLA Law Review online publication Discourse accompanying this Article: Wendy Bach, Doron Dorfman, Mary Fan, Eve Hanan, Jamelia Morgan, Jennifer Oliva, Brenda Smith, and Madalyn Wasilczuk.

By LRIRE