Claims of Injury Involving Induced Abortions by Teenagers without Parental Notice or Consent
Thomas W. Strahan, J.D., Editor

Association for Interdisciplinary Research in Values and Social Change
Research Bulletin Vol. 10 No.4 January/February 1997
Reproduced with Permission

Substantial numbers of pregnant adolescents do not consult either their mother or father prior to obtaining an abortion. A Minnesota study found that 43% of adolescents obtaining abortions used the court bypass option to avoid disclosure to a parent.1 Male partners have been found to be more likely to be consulted than parents, once pregnancy is confirmed (83% vs. 56%).2 An Atlanta study of adolescents, obtaining abortions at five different private facilities, found that 51% confided in their parents.3 According to the Centers for Disease Control, 20% of the reported abortions in the U.S. are among those who are 19 years of age or less.4

The following reported cases involve situations where neither parent was notified or aware that their adolescent daughter had obtained an abortion.

Claims of Physical Injury

In Baldaraz vs. Granbury School District, the parents of a 17 year old high school student brought suit in U.S. District Court in Fort Worth, Texas, after she suffered a uterine infection and psychological distress, following an abortion without her parents’ knowledge. According to the complaint, a high school drug awareness counselor discovered that the girl was pregnant and called her out of class to urge her to have an abortion. The suit detailed elaborate plans, made by the counselor, in order to procure the abortion. According to the complaint, the parents had no knowledge of the abortion until the next day, when their daughter began experiencing “extreme pain and discomfort.” That same day a doctor diagnosed the girl as suffering from a severe uterine infection, as a result of an incomplete abortion. According to the complaint, the counselor denied any involvement in arranging for the abortion when the girl’s parents met with her and other school officials a week later. The principal of the school was said to have labeled the girl’s account of the incident as a “hallucination.”5

According to press reports, the school counselor told the girl that she had “too much going for her to be tied down with a baby,” suggested several abortion-clinics, and said that a friend of the counselor would provide half of the fee if the father of the baby provided the rest. According to the press reports, it was alleged in the suit that the counselor told the girl not to tell her parents about the abortion, and was quoted as saying “Parents basically aren’t for abortion. They either don’t agree with them, or they don’t believe in them.” The suit was eventually settled for an undisclosed amount.6

In a Tennessee case of Roddy vs. Volunteer Medical Clinic 926 S.W.2d 572 (Tenn. App. 1996), the plaintiff, Tanisha Roddy, age 16 and her mother, Janet Roddy, brought a medical malpractice action for perforation of her uterus, against Edgar Perry, the doctor who performed the abortion and Volunteer Medical Clinic, the facility where the abortion was performed. The complaint also alleged violation of the Tennessee Parental-Consent-for-Abortions-by-Minors Act, which was subsequently found to be unconstitutional and not considered. According to the case report, the plaintiff Tanisha Roddy became sexually active in 1990, and had an ongoing relationship with a young man. In July, 1990 she spent two weeks visiting her aunt in New York City, and while there she sought medical treatment for a vaginal infection from her aunt’s ob/gyn. At the same time she requested a pregnancy test which confirmed that she was pregnant. She called the man in Tennessee with whom she had been sexually active, but help was not forthcoming from him. She then called another aunt in Knoxville, Tennessee, who she was aware previously had had an abortion and they discussed her options. Tanisha did not want her mother to become aware of her pregnancy and decided to have an abortion. Tanisha returned home and in accordance with pre-arranged plans requested of her mother that she be granted permission to stay with the aunt in Knoxville for several days. The mother granted permission to do so.

She went to Knoxville and went to the abortion facility accompanied by her aunt’s roommate. At the clinic she gave her aunt’s address and phone number in Knoxville as her own address and phone number, “because she did not want anyone to contact her family” besides her aunt or herself. She was one month short of her 16th birthday. She was counseled by an intake person at the facility, and signed a Consent-to-Abortion form which granted consent to a Dr. Manning to perform an aspiration abortion, under paracervical block anesthesia. An ultrasound was performed indicating that she was 14-16 weeks pregnant. Dr. Manning did not do the abortion as he was leaving town that night. She returned to the abortion facility the next day along with her aunt and the aunt’s roommate, signed another Consent-to-Abortion form to be performed by Dr. Perry. The case report does not indicate whether the second consent form was for an aspiration abortion under paracervical block, but apparently it was the same procedure. Nor does the case-report indicate whether or not Dr. Perry knew of the results of the ultrasound examination.

According to the report, when the abortion was about 80% complete, the doctor testified that she made a sudden movement, causing the instrument which Dr. Perry was using inside the uterus to perforate the wall of the uterus. Dr. Perry terminated the procedure and tried to remove the remaining portion of the fetus with forceps. However, this was not successful, and she was transferred to a nearby hospital, where the perforation was repaired and the abortion was completed. A medical report, signed by the treating doctor, indicated that, to the best of his knowledge, she suffered no permanent ill effects as a result of these events. However, she continued to be sexually active since the abortion. The case was dismissed on motion of the defendants, and affirmed on appeal, because the plaintiffís expert had failed to establish the applicable standard of care for a medical malpractice case.


The plaintiff’s case was greatly hampered by the lack of a qualified expert to establish the appropriate standard of care. This was particularly difficult to do, especially since the court demanded that the standard of care be determined based on that applicable to the local community. The fact that the State law, which related to minorsí consent-to-abortion, had been held unconstitutional, could not be asserted also hampered the plaintiff in successfully asserting his claim. Under those circumstances it may be virtually impossible to get a local abortionist to testify, and other ob/gyns in the community are likely not to be familiar with abortion procedures. Further, from the facts presented, there was evidence of medical malpractice. For example, it appears that a suction abortion was attempted despite the fact that an ultrasound indicated that the girl was in the second trimester. This would increase the risk for perforation of the uterus and may also have disqualified the doctor, who may not have been trained in second-trimester-abortion procedures. Also, the doctor performing the abortion may have failed to meet the proper standard of care by, among other things, failing to properly examine the patient, by determining the uterine position and size, or ascertain any uterine anomalies, underestimate the length of gestation, failing to take into account the length of gestation, selecting the wrong method of abortion, selecting the wrong cannula, or attempting to use a curette or other instrument when it was not necessary, or failing to position his fingers to protect against abrupt relaxation of the cervix.

The doctor who completed the abortion could not state with any degree of certainty that the plaintiff suffered no permanent effects, as her future ability to bear a child may have been compromised. Studies of young teenagers have found a high rate of fetal loss in pregnancies that followed abortions.7 Teenagers are also at a higher risk for cervical injury during suction-curettage-abortion than adult women. This may include microfractures of the cervix, which can lead to cervical incompetence, premature delivery, and pregnancy complications.8 Also, teenagers are at significantly increased risks for post-abortion infections, such as pelvic inflammatory disease, or endometritis compared to adults.9 In addition, a substantial number of well-designed studies have found that the risk of breast cancer is significantly increased if the first pregnancy of a teenager ends in abortion.10

Studies have shown that a teenager may decide for childbirth or abortion, depending upon whether or not she knows of someone who has given birth to a child or has had an abortion.11 In this case, Tanisha Roddy knew an aunt who previously had had an abortion. This was a likely factor, which influenced her to have an abortion. The aunt was not likely to have the quality of objectivity, because many women are known to attempt to rationalize their own abortion by convincing another to obtain one.

Also, Tanisha was temporarily not living with her parents, when she found out she was pregnant, but was not yet emancipated. It has been shown that minors, not living with their mothers, are much less likely to consult with the mother, prior to pregnancy decision-making, compared to minors who are living with their mother.12

Claim of Loss of Federal Civil Rights

In Arnold vs. Board of Education of Escambia County, Alabama, 880 F2d305 (11th Cir 1989), the parents of minor students in a public school brought civil rights claims against a school guidance counselor, the vice-principal and the school board, for allegedly coercing a student into having an abortion. The plaintiff’s alleged violations of their First, Thirteenth and Fourteenth Amendments as well as civil rights claims under 42 U.S. C.1981 (equal rights under the law), 1983 (deprivation of rights) and 1985 (conspiracy to interfere with civil rights). The trial court had granted a defense motion to dismiss the claims, but the Federal Court of Appeals reversed. The Court of Appeals held that: (1) coercing a minor to abort violates the minor’s constitutionally protected freedom to choose whether to bear or abort her child, under the 14th Amendment; (2) allegations by a minor high school student that she was coerced by a school guidance counselor and a vice-principal were sufficient to state a cause of action under 42 U.S. C.1983, and (3) allegations by a student that school guidance counselor imposed her will upon a student to have an abortion, and that abortion was prohibited by the student’s religious beliefs, stated a cause of action for violation of the student’s free exercise rights under the First Amendment, and that (4) Parents have a constitutional right to decide, free from unjustified governmental interference, matters concerning growth, development, and the upbringing of their children. In this case, it was claimed that counselors coerced the minor girl and the putative father, also a student, from discussing the decision with their parents, provided work to earn money to pay for the abortion, paid $20 to a student to drive the student to obtain an abortion, and allegations that black students were counseled to have abortions while white students were counseled to carry to term, sufficiently stated a cause of action. The case was remanded to the trial court for further proceedings. The case was ultimately dismissed by the trial court after a motion for summary judgment, to which plaintiffs did not respond. 754 F. Supp. 853 (S.D. Ala 1990).


Teenagers have been found to frequently violate their conscience or beliefs, when they obtain an abortion. A San Diego study of young women, aged 14-20 found that over 60% had strong guilt following abortion.13 A North-Carolina study also found that adolescents obtaining abortions, frequently violated their own beliefs about abortion in the process.14

If pregnant teenagers attend religious services regularly, they have been found to be less likely to notify at least one parent, compared to teenagers who, prior to obtaining an abortion, never attended religious services.15 Those who are more religious also are significantly more likely to believe that abortion is morally wrong and a violation of religious beliefs. In addition to claims, based on the First Amendment, violation of freedom of religion, claims of teenagers or parents might also be brought under the Religious Freedom Restoration Act.

Claims of Emotional Injury

In a Texas case of Clement vs. Riston, M.D., Jefferson Co., Texas, 1990, the plaintiff, a minor, suffered severe emotional distress after she underwent an abortion performed by the defendant doctor. The plaintiff claimed that the defendant failed to get proper consent from the parent before performing the abortion. The defendant contended that the parental consent code was unconstitutional, and that any emotional distress was caused by the plaintiff’s relationship with one of her high school teachers and the football coach. A verdict of $20,000 was returned for the plaintiff.


The man who had sexual intercourse with the minor girl, which resulted in her pregnancy and subsequent abortion, appeared to be several years older than the minor. Recent studies have demonstrated that it is frequently the case that teen pregnancies result from males having sex with teenagers who are much younger than themselves, which may be in violation of state criminal laws, prohibiting sex with a minor. For example, a recent Population Reference Bureau study found that about two-thirds of births to teenage girls nationwide are fathered by adult men age 20 or older.16 The Alan Guttmacher Institute reported in 1994 that six of ten girls, who had sex before age 15, were coerced by males an average of six years older than the female.17 A Washington State study of 535 women, who became pregnant as adolescents, found that two-thirds had been sexually abused and 44% had been raped. The average age of the adolescent at first rape was 13.3 years, while that of the perpetrator was 22.6 years.18

The verdict in the case also appeared to be too low, and it is likely that the minor suffered a substantial injury, for which she was not adequately compensated. One reason is that the plaintiff was at long term risk for emotional injury. Women, who have had abortions as teenagers, are more likely than other women to join such groups as Women Exploited by Abortion, participate in post-abortion support groups, because of guilt, grief or loss, or because they poorly assimilate their abortion experience and suffer severe adverse long term reactions.19 Teenagers have also been reported to be more likely to lose their sense of idealism and innocence after a traumatic event.20

In Boykin vs. Magnolia Bay, Inc. 570 So.2d 639 (Ala. 1990), the parents of Rhonya Boykin, a minor, brought a claim for damages including intentional infliction of emotional distress (outrage), trespass, and assault and battery on behalf of themselves and also on behalf of their minor daughter, against an abortion-facility for performing an abortion on their daughter without their knowledge or consent. Their daughter had made the decision to have an abortion, after discussing it with her boyfriend, the child’s father, and also a girlfriend. The child’s father had obtained the funds for the abortion from his own father, which he said were necessary for an abortion, because the girl had been told by a doctor that she could not carry a pregnancy to term. However, this statement was not correct. However, she did not tell her parents, who subsequently learned of it several months later. She was accompanied to the abortion facility by her girlfriend, who represented herself as her sister, as well as the boyfriend. At the facility Rhonya lied about her age, and represented to them that she was over 18 years of age, when, in fact, she was only 15. No one at the facility asked for verification of her age. The plaintiffs did not contend that the abortion procedure was performed incorrectly or that their daughter sustained any injuries or complications thereafter.

An Alabama court ruled that the minor girl was in pari delicto (in equal guilt or fault) as a result of her misrepresentation and could not recover damages. The court also barred the parents from making any derivative claims, based upon any rights of their daughter. They also dismissed the parental claim of outrage, because the parents had not been present at the time of the abortion. The parental rights claim of the parents, because it had not been based on the State statutory parental consent law, was also dismissed. It was not clear from the record whether or not the parents were still able to reassert their statutory claim in an amended complaint or new action.


In this case the court exclusively relied on a statutory claim of parental rights, and refused to consider any parental rights claim, based upon the common law, case law or fundamental rights of parents under existing Supreme Court decisions. Apparently, this occurred because the court believed that abortion case law preempted any of these claims.

The Alabama Parental Consent to Performing Abortion Upon a Minor legislative intent is (1) stated to be protecting minors against their own immaturity, (2) fostering the family structure and preserving it as a viable social unit, and (3) protecting the rights of parents to rear children who are members of their own household. However, the Alabama State courts have made little effort to protect the family structure or rights of parents, but instead, allow a court parental by-pass procedure if the court deems the minor to be mature, and apparently assume the abortion to be in her best interests. See “Ex Parte Anonymous” 618 So.2d 722 (Ala. 1993); “In Re Anonymous”, 660 So.2d 1022 (Ala.Cir.App.1995); Code of Alabama (1975), Section 26-21-1 thru 26-21-8.

In a Missouri case, of Eidson vs. Reproductive Health Services, 863 S.W.2d 621 (Mo. App.E.D., 1993) the plaintiff, Geneva Eidson, the single mother of a minor girl who obtained an abortion and committed suicide shortly thereafter, brought a wrongful death action for medical negligence, arising out of her daughter’s suicide. The daughter, Sandra Kaiser, had a history of behavioral and emotional problems for which she received counseling and psychiatric therapy. At age 7 Sandra had witnessed the stabbing death of one of her half brothers. At age 11 she was diagnosed with a conduct disorder. By age 12 her problems included drinking alcohol, running away from home, temper outbursts, skipping school, crying and nightmares about her brother’s death. She was hospitalized at least twice and had received outpatient therapy and medication for unmanageable behavior, anxiety and aggressive behavior. In the spring semester of her death she received “F’s ” in every class and officials reported poor attendance. In the fall semester of her death she missed 37Ω days of the 51 days of school.

In October 1984 at age 14, Sandra told her 21 year-old half-sister Karen Flynn that she thought she was pregnant. Her half-sister went with her to Planned Parenthood for a pregnancy test. Sandra discussed the pregnancy with her half-sister and decided to have an abortion. Her half-sister made an appointment for her at the defendant’s abortion facility and attended the counseling session with Sandra. According to Karen Flynn, Sandra expressed no ambivalence about the abortion and told the abortion counselors that she thought she was too young to have a child. The defendant’s records indicate that Sandra told them her mother knew about the abortion and supported it and had given her the money to pay for it. Plaintiff testified however, that she did not know about the abortion and had given money to the half-sister to pay bills. Three days after the initial counseling session, Sandra returned with her half-sister to have the abortion. She signed a consent-to-abortion form. Karen Flynn signed the form in the space for parent/guardian. Together they completed a form that requested information under the headings: “Social History,” “Menstrual History,” “Contraceptive History,” and “Medical History.” They answered “no” to the question under “Medical History” which asked, “Have you ever received counseling? (Do not include any counseling for this pregnancy.” ) They also answered “no” to the question, “Have you even been hospitalized other than for childbirth?” Karen Flynn was aware of Sandra’s counseling and hospitalization history, but testified they did not report it on defendant’s forms, because they believed the questions referred to counseling for pregnancy and hospitalization for physical treatment. In a film entitled “First Trimester Informed Consent", seen by Sandra at the abortion facility, it was stated: “A few women have negative emotional feelings after an abortion. You may feel slightly depressed, but those feelings are normal. Hormones, which were increased during pregnancy, have now suddenly been lowered in your body, and that makes changes, which can result in feelings of depression, but severe depression is not to be expected. If you are severely depressed after this abortion it may be that your feelings about ending a pregnancy have not yet been completely resolved. You should see a counselor in an agency near you, either the agency that referred you here, a family service agency, Planned Parenthood affiliate, or your clergyman or come back here. Call us. We are here to serve your physical and emotional needs. We want to help, but we need you to call us.”

According to several witnesses Sandra became very depressed, stayed in her room and cried a lot after the abortion. About 3 weeks after the abortion Sandra’s mother overheard her telephone conversation with her boyfriend, that he had gotten somebody else pregnant, and that she was going to jump off a bridge and kill herself. After the conversation with the boyfriend, she stomped off and left the house. About 30 minutes later, Sandra jumped off a bridge into the path of a car traveling below. A second car hit her while she was on the ground. She died the next day of multiple injuries.

At the trial, plaintiff’s expert testified that Sandra had been suffering from a major depression at the time of her death and had been for several weeks, that the suicide was a direct consequence of this depression, and that the abortion was the “straw that broke the camel’s back.” The expert also testified that depression may be due to hopelessness, a sense of worthlessness and a sense of loss from the abortion. However, the court ruled that because the plaintiff had not demonstrated that the suicide was committed while her daughter was insane or suffering from an uncontrollable impulse, that the plaintiff failed to present a case that could be submitted to a jury on the issue on whether or not defendant’s failure to obtain a psychiatric history or failure to monitor her mental health, proximately caused her suicide. Therefore, plaintiff’s case was dismissed. Further, since the suicide occurred during the time that the Missouri law, governing consent of minors to abortion was enjoined by the Federal courts, the statute could not be used to define a duty of care or standard of conduct in the case.


The plaintiff’s case was not even able to be heard by a jury because the legal standard under Missouri law required a showing that the minor was insane or acted under an irresistible impulse. This was a very difficult standard to meet. The fact that the Missouri law, regarding consent of a minor to an abortion, was enjoined thus was very harmful because it could not be successfully asserted as the basis for a cause of action.

The fact that serious emotional injury can occur from induced abortion was greatly downplayed by the abortion facility. This may have been a factor in the belief of the minor and her half-sister that the abortion facility was only concerned about physical aspects. A study published in 1981 had found that women, having an induced abortion, were at significantly greater risk for admission to a psychiatric hospital compared to childbearing women. The risk for psychiatric admission was significantly higher for single or separated women compared to married women.21 Similarly, the failure to take a psychiatric history failed to take into account a Canadian study that found that women, with a previous psychiatric history prior to abortion, were significantly more likely to have a psychiatric disorder, including suicide attempts, following abortion, compared to post-abortion women without any previous psychiatric history (21% vs. 8%).22 Another study, published in 1981, reported suicide attempts among adolescents on anniversary dates of their abortion.23 Since 1987, a medical textbook on obstetrical decision-making has included psychosocial history as part of the necessary counseling procedures prior to induced abortion.24 In a study published in 1989 it was found that women, who reported poorly assimilating their abortion experience, were more likely to attempt suicide following abortion, if they had abortions as teenagers, compared to women who had abortions as adults.25 A recent Finnish study published in 1996 has also reported that the incidence of suicide is significantly greater following induced abortion, compared to miscarriage or childbirth.26


The cases of teenage abortion, without parental notice of consent and where there were subsequent injury claims, indicate that adverse physical and psychological risks were significantly understated or believed to be minimal. This was evident in the statements of medical doctors, counseling information provided by abortion-facilities, and the attitudes of adults who were involved.

Also, frequently there was lying or misrepresentation by those involved. This included minors lying about their age or address, or adults misrepresenting that they were the parent or guardian, or other adults.

In addition, school counselors actively sought and encouraged pregnant teenagers not to notify their parents of the pregnancy. Abortion-facilities also failed to verify statements, made by those seeking abortions or those who accompanied them.

In two cases the fact that parental notice or consent-laws had been held unconstitutional and could not be successfully asserted was a major factor in dismissal of the case. In one instance, where a teenager suffered physical injury, the law would have helped in determining the standard of care, and whether or not an informed consent was obtained. In another instance, where a teenager committed suicide shortly after an abortion, the plaintiffs were required to demonstrate that the minor was insane or acted under an irresistible impulse in order to demonstrate a possible causal connection between the conduct of the abortion-facility personnel and the suicide. If the minor-consent-law had been in effect, sufficient evidence likely could have been presented to show that there was a violation, which at least would have permitted the case to be submitted to a jury. It is apparent that current abortion-law is frequently not helpful in successfully asserting claims on behalf of teenagers who are injured by abortion.

In addition, there is a need to educate judges, doctors, other professionals, and counselors, relative to the risks from abortion, as well as members of the general public who incorrectly believe that an abortion is the solution to a teenage pregnancy.


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25The Connecticut Mutual Life Report on American Values in the 80s: The Impact of Belief, Connecticut Mutual Life Ins. Co: Hartford, Conn. (1981); Strahan, Thomas “Factors in Pregnancy Decision-Making by Teenagers”, Association for Interdisciplinary Research in Values and Social Change 7(4): 1-8, Jan/Feb 1995; Strahan, Thomas “Induced Abortion as a Violation of Conscience of the Woman”, Assoc. for Interdisciplinary Research in Values and Social Change 8(4): 1-8, Sept/Oct 1995 [Back]

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