About This Case Study

In September 2020, a nurse named Dawn Wooten filed a whistleblower complaint alleging that women detained at the Irwin County Detention Center in Georgia, an ICE-contracted facility, had been subjected to coerced and medically unnecessary hysterectomies. The allegations triggered congressional inquiry, a class-action lawsuit, an investigation by the Department of Homeland Security's Office of Inspector General, and, eventually, the closure of the facility's ICE contract. The ACLU's reporting on the case framed it as a recurrence of an older American pattern: the use of medical procedures, carried out under the cover of institutional confinement, to manage the reproduction of populations the state has deemed unfit for full citizenship.

This case study takes the ACLU's framing seriously as a hypothesis to test. The exercise pairs the ACLU's account with Natalia Molina's Fit to Be Citizens?, which traces how public-health discourse in late-nineteenth- and early-twentieth-century Los Angeles racialized Mexican, Chinese, and Japanese residents by treating them as carriers of disease and threats to the national body — and asks whether the ICE case represents a continuity with Molina's history, a transformation of it, or some combination. The analytical move is to use a specific historical framework to read a present-day event with precision, rather than treating the past as a vague reservoir of "lessons" or treating the present as wholly without precedent.

Before You Begin

Pre-reading is required:

• American Civil Liberties Union. "Immigration Detention and Coerced Sterilization: History Tragically Repeats Itself." 2020. (aclu.org)
• Natalia Molina, Fit to Be Citizens? Public Health and Race in Los Angeles, 1879–1939 — at least the introduction and one substantive chapter, or your notes on the work as encountered in the unit

While reading the ACLU account, keep these prompts in mind:

• Who is the institutional actor in this case? Who carries out the procedures, and under what authority?
• Whose body is the object of the procedure, and on what legal status do they stand at the moment of the procedure?
• What does the ACLU mean by "history tragically repeats itself"? Which history is it pointing to?

While reviewing Molina, keep this prompt in mind:

• What does Molina mean when she says that public-health discourse racialized immigrant populations? What is the mechanism — what does the racializing actually consist of?

The Exercise

Phase 1: Reading the ACLU Account (8–10 minutes)

Take a single careful pass through the ACLU article. As you read, identify and note:

1. The factual core. Who, what, where, when. The names and roles of the parties; the facility; the procedures alleged; the timeline; the institutional response.
2. The historical claim. The ACLU's title positions this as a repetition. What historical events does the article invoke as the precedent — Indian Health Service sterilizations in the 1960s and 1970s, the California prison sterilizations through 2010, Puerto Rico, North Carolina's eugenic sterilization program, the broader American Eugenics Movement? Identify what the article actually claims is being repeated.
3. The framing words. Note three or four specific words or phrases the ACLU uses to characterize the case — for example, "coerced," "history," "reproductive coercion," "control of immigrant bodies." These words carry the argument.

For groups: each member produces their own notes in this phase. Do not share yet.

Phase 2: Applying Molina's Frame (10–12 minutes)

Molina's argument, in compressed form, is that public-health discourse in early-twentieth-century Los Angeles racialized Mexican, Chinese, and Japanese immigrants by treating their bodies as health threats to the national body — and that the racializing operated through specific institutional practices: quarantines, housing inspections, vaccination programs, the regulation of food and laundry businesses, and the medical examination of arriving immigrants. The racial categories that emerged were not just attitudes or beliefs; they were instituted in city ordinances, public-health bureaucracies, and immigration screening. Public health, in this account, was a major site at which racial classification was made operational.

Now bring Molina's framework to the ICE case. Work through the following questions in your notes:

• The institutional site. Molina's site is municipal public health (city health departments, immigration screening at the border, housing inspections). The ICE case's site is federal immigration detention. Are these the same kind of institutional space, a related kind, or a different kind? Where does the analogy hold, and where does it break?
• The mechanism. Molina shows public health producing racial categories through quarantine, inspection, and exclusion. What is the mechanism in the ICE case? Detention itself? The medical procedure? The selective application of the procedure? Specify.
• The discourse. Molina shows how a vocabulary of disease, contagion, and unfitness did racializing work without naming race directly. Is there a comparable vocabulary at work in the ICE case? What does the contemporary vocabulary borrow from earlier discourse, and what is genuinely new?
• The citizenship dimension. Molina's title — Fit to Be Citizens? — names citizenship as the stakes. For Molina, public-health screening shaped who could become a citizen and on what terms. In the ICE case, the detained women are non-citizens by legal status. Does this difference change the analogy, or sharpen it?

For groups: distribute the four questions across members or pairs. Reconvene after eight minutes to compare answers.

Phase 3: Continuity, Transformation, or Both? (8–10 minutes)

You now have what you need to address the question the unit's reflection prompt asks: does the ICE case represent a recurrence of historical biopolitical logic, a transformation of it, or both?

Resist the temptation to answer "both" too easily. Both is often correct but rarely informative — the analytical work is in specifying where the continuity holds and where the transformation operates.

Develop, in writing or discussion, a two-part answer:

1. The continuity claim. Specify one element of the ICE case that you would describe as continuous with the historical pattern Molina (or Stern, if you have read her) examines. Name the element precisely — not "racism" or "the state" in general, but a specific institutional practice, vocabulary, target, or rationale that travels from the historical case to the contemporary one.
2. The transformation claim. Specify one element that has been transformed — that is not simply present in the historical record. This might be a legal framework, a screening discourse, a technology, an institutional actor, or a mode of public visibility (whistleblowing, social media exposure, federal litigation). Again, name the element precisely.

Where the two claims meet — where the continuous element and the transformed element are bound together in the same case — is where biopolitics, as the unit's central concept, is doing its work.

For groups: each member presents their continuity claim and their transformation claim in turn. The group then identifies whether the continuity claims cluster around the same elements, and whether the transformation claims do.

Closing Reflection

Complete this thought in two or three sentences:

The ICE case is a continuity with the history Molina (and the broader eugenic record) traces in __________. It is a transformation of that history in __________. Reading the two together changes my sense of biopolitics because __________.

The value of the sentence is in the precision of what you name — in the words you find yourself choosing, and in what you find yourself unable to fit.

A Note on Modes

Solo mode. Work through the three phases in order, writing brief notes at each step. The Phase 3 two-part answer is the central artifact; keep it for reference when answering Question 4 (on Molina and the ICE sterilization case study) in the unit's Questions for Reflection.

Group mode (3–6 people). Designate a timekeeper. Phase 1 is individual; Phase 2 works well distributed across members or pairs; Phase 3 benefits from full-group discussion. If group time is short, the closing reflection can be assigned as individual writing after the session.

After the Case Study

• Return to Question 4 in the unit's Questions for Reflection, which asks you to articulate the continuity or the rupture between Molina's history and the ICE case. The Phase 3 two-part answer is the seed for this response.
• To extend the exercise: the Department of Homeland Security's Office of Inspector General released a report on the Irwin County allegations in 2022, and a class-action lawsuit filed by detained women resulted in a settlement. Following the institutional response from the 2020 whistleblower complaint to the 2022 settlement adds a layer of analysis that the ACLU article, written at the moment of the initial allegations, cannot supply.
• For a longer historical arc, Alexandra Minna Stern's Eugenic Nation (Key Scholarship) traces sterilization practices in California from the early twentieth century through the documented cases in California prisons that continued into the 2010s. Reading Stern alongside the ICE case extends the continuity claim from Molina's early-twentieth-century framework into a more recent and proximate institutional history.