Abstinence-only-until-marriage programs deny young people necessary information to protect their health. Such programs have an extensive history of disseminating misinformation about the effectiveness of condoms and other contraceptives, if those methods were mentioned at all, and the federal eight-point definition of “abstinence education” limits discussion of contraception. This violates the fundamental principle that all people have a fundamental right to be given accurate information that can help protect their health. In the United States National HIV/AIDS Strategy (NHAS), which was unveiled on July 13, 2010, the administration of President Barack Obama outlined how it intends to achieve the president’s goal that “[t]he United States will become a place where new HIV infections are rare and when they do occur, every person, regardless of age, gender, race/ethnicity, sexual orientation, gender identity or socio-economic circumstance, will have unfettered access to high-quality, life-extending care, free from stigma and discrimination.”[1] In order to achieve the first goal of reducing new HIV infections, the NHAS focuses heavily on the importance of educating people about HIV/AIDS across the life span, including “access to a baseline of health education information that is grounded in the benefits of abstinence and delaying or limiting sexual activity, while ensuring that youth who make the decision to be sexually active have the information they need to take steps to protect themselves.”[2] By creating the NHAS, the United States has joined the international community in formally recognizing the vital role that comprehensive sexuality education programs play in preventing the transmission of HIV as well as the necessity of ensuring that these programs properly address the health needs of all people.
 
Abstinence-Only-Until-Marriage Programs:
 
Violate International Human Rights Guidelines
 
Access to comprehensive, medically accurate information about sexual health, including reproductive health and HIV/AIDS, is not only a major public health concern; it is recognized as a human right. At the most basic level, several international agreements recognize that all people have the right to “seek, receive and impart information of all kinds,” including information about their health.[3] Young people, in particular, are often both most in need of and least likely to receive this information. Denying young people access to comprehensive sexuality education stands in direct violation of major international agreements that require governments to provide unencumbered, non-discriminatory access to education about sexuality, including HIV prevention.
 
On the international stage, the United States has repeatedly endorsed the right to education about sexuality through its participation in forging consensus agreements such as the International Conference on Population and Development Programme of Action (ICPD PoA, the Beijing Declaration and Platform for Action, and the United Nations’ Millennium Development Goals. The United States has also signed, though not ratified, three international treaties that establish a right to health education and information: the Convention on the Rights of the Child (Child’s Convention), the Convention on the Elimination of All Forms of Discrimination Against Women, and the International Covenant on Economic, Social and Cultural Rights. The human rights treaties ratified by the United States—the Convention on the Elimination of All Forms of Racial Discrimination (CERD)and the International Covenant on Civil and Political Rights (ICCPR)—also address this issue. CERD specifically provides for equal access to information regarding health, while the ICCPR sets out a more general right to information.
 
Adolescents have been a special focus of concern as the international community addresses health and human rights. The approach reflected in many international documents is one that reaffirms the rights of adolescents to accurate information that will enable them to make informed decisions about their health. For example, the most comprehensive agreement on sexual and reproductive rights, the ICPD PoA, requires governments to ensure that information and services are available to adolescents “to help them understand their sexuality and protect themselves from unwanted pregnancies, sexually transmitted diseases, and subsequent fertility.”[4] The most comprehensive agreement on the rights of young people, the Child’s Convention, likewise requires governments to “ensure that all segments of society, in particular parents and children, are informed, have access to education and are supported in the use of basic knowledge of child health.”[5] The Committee on the Rights of the Child, the United Nations body responsible for monitoring the implementation of the Child’s Convention, specifically states in its general comment on HIV/AIDS that children have the right to access adequate information related to HIV/AIDS prevention. In addition, the UN General Assembly Special Session on HIV/AIDS, Declaration of Commitment on HIV/AIDS highlights the importance of involving young people “in planning, implementing and evaluating HIV/AIDS prevention” programs.[6]
 
The Rights of Women and Girls
In addition to basic guarantees for all people to the highest attainable standard of health and free access to information, several agreements promise freedom from harmful gender stereotypes that are often reinforced by abstinence-only-until-marriage programs. The Convention on the Elimination of All Forms of Discrimination against Women states that governments must take all appropriate measures to
 
“modify the social and cultural patterns of conduct of men and women, with a view to achieving the elimination of prejudices and customary and all other practices which are based on the idea of the inferiority or the superiority of either of the sexes or on stereotyped roles for men and women.”[7]
 
Many abstinence-only-until-marriage programs foster gender stereotypes pertaining to sexuality, and these stereotypes exacerbate the vulnerability of women and girls. Furthermore, promoting marriage as a protective factor denies the fact that women remain vulnerable in marriage, especially in areas of the world where the fastest growing rate of HIV-infection is among married monogamous women. The Berlin Call to Action,which was released at an international forum to commemorate the 15th anniversary of the ICPD PoA and discuss how to continue pursuing its goals, further emphasized the importance of ensuring that accurate information regarding sexual and reproductive health is communicated to women and girls, as well as “eradicat[ing] discrimination against girls . . . advanc[ing] gender equality and equity and empower[ing] girls and women.”[8]
 
The Rights of LGBT Individuals
International law and human rights standards require that all people, without discrimination, have access to vital HIV-prevention information. In addition, some jurisdictions in the United States have state laws specifically protecting the civil rights of lesbian, gay, bisexual, or transgender (LGBT) individuals and prohibiting discrimination on the basis of sexual orientation. By definition, abstinence-only-until-marriage programs discriminate on the basis of sexual orientation. These programs typically deny or ignore the very existence of LGBT individuals. By offering marriage as the only answer to the risk of contracting HIV and ignoring the fact that same-sex marriage remains illegal in most places, these programs wrongly teach that there is no way for LGBT individuals to be sexually active and remain safe. In fact, when same-sex sexual behavior is addressed, these programs often suggest that it is inherently wrong and to blame for the AIDS pandemic.
 
This reinforces existing social stigma and prejudice against LGBT individuals. In fact, in the areas of the world hardest hit by the AIDS pandemic and most reliant on foreign aid, “homosexual” acts are often criminalized. In these places and the United States, LGBT individuals are routinely discriminated against, marginalized, and even assaulted. Ending HIV/AIDS requires that the human rights of LGBT individuals are respected and that the human rights violations that keep these communities hidden and beyond the reach of prevention efforts are ended. The UN Guidelines on HIV/AIDS and Human Rights advise that countries enact anti-discrimination and protective laws “to reduce human rights violations against men having sex with men, including in the context of HIV/AIDS, in order, inter alia, to reduce the vulnerability of men who have sex with men to infection by HIV and to the impact of HIV/AIDS. These measures should include providing penalties for the vilification of people who engage in same-sex relationships, giving legal recognition to same-sex marriages and/or relationships.”[9]
 
The global community already recognizes the centrality of sexual and reproductive health and rights to building a better world. By continuing to fund abstinence-only-until-marriage programs at home and abroad, the United States is lagging behind countries across the globe and failing to fulfill its potential to be a global leader on health and human rights.
 
Violate Freedom of Speech
 
In violation of the First Amendment of the United States Constitution, federally funded abstinence-only-until-marriage programs restrict young people’s access to much needed health information and limit their learning to only the “approved” messages put forth by the government in the eight-point definition of “abstinence education.” Recipients of federal abstinence-only-until-marriage funds and the teachers who provide these federally funded programs to their students essentially operate under a gag order that censors the communication of vital information.
In order to receive funding, grantees must offer programs that have the “exclusive purpose” of teaching abstinence, including the notion that “a mutually faithful monogamous relationship in the context of marriage is the expected standard of human sexual activity” and that “sexual activity outside of the context of marriage is likely to have harmful psychological and physical effects.” (See What Programs Must Teach for the full eight-point definition.) Recipients of federal funds and the teachers in the classroom operating with this funding may not provide youth any information that is inconsistent with this very narrow eight-point definition.
 
The federal government’s prohibition on giving youth the information they require to protect their health violates its responsibility to ensure that all people have the tools they need to lead healthy and complete lives. Following an exhaustive review of programs that received abstinence-only-until-marriage funding, as well as comprehensive sexuality education programs, the Society of Adolescent Health and Medicine (SAHM) declared that by denying basic health information to youth, the government ignores its “obligation to provide accurate information to [its] citizens and eschew the provision of misinformation” and that “such obligations extend to government-funded health education and health care services.”[10] In addition, SAHM states that restricting the information that educators and health care providers may give to their students and patients forces them to defy the ethics of their professions, as they are required “not [to] withhold information from a patient in order to influence their health care choices”[11] Furthermore, SAHM suggests that “[w]ithholding information on contraception to induce [youth] to become abstinent is inherently coercive.”[12]
 
Abstinence-only-until-marriage programs prohibit teaching full and complete sexual health information. As a result, vital health information about contraception, including condoms, is censored, leaving young people at risk of unintended pregnancies and sexually transmitted diseases, including HIV/AIDS.
 
Violate Separation of Church and State
 
In the United States, federal law does not permit government-funded programs to convey religious messages or impose religious viewpoints or practices. Nonetheless, for nearly the last three decades many abstinence-only-until-marriage programs have done precisely that by receiving federal funding and thus using taxpayer money to endorse religious beliefs and underwrite religious activities. In fact, many federally funded abstinence-only-until-marriage programs contain religion-based teachings about “proper” sexual behavior and values, in violation of the First Amendment’s guarantee of the separation of church and state.
The curricula used in many abstinence-only-until-marriage programs were developed by religious groups whose views on sexual orientation, non-marital sex, contraception, and abortion are by no means universal. Yet, it is only because of intense public pressure and legal challenges, such as those brought by the American Civil Liberties Union (ACLU), that some domestic programs have removed their overt proselytizing.
 
Since the very beginning of federally funded abstinence-only-until-marriage programs, advocates and experts have questioned the religious tenor of these programs. Soon after Congress passed the first federal measure to promote “abstinence education,” the Adolescent Family Life Act (AFLA), a lawsuit was filed that challenged the programs for violating the Constitution’s mandated separation of church and state. Of particular concern are
  • grant applicants being required to explain how they would involve religious organizations (among other groups) when providing services
  • religious organizations being were allowed to receive funds
  • program goals coinciding with certain religious beliefs
In her concurring opinion on the case, Supreme Court Justice Sandra Day O’Connor affirmed that “public funds may not be used to endorse [a] religious message.[13] While the Court did not find the text of AFLA to be in violation of the First Amendment, it remanded the case and directed the District Court to evaluate whether or not AFLA funds “flow[ed] to grantees that can be considered ‘pervasively sectarian’ religious institutions,” or “whether in particular cases AFLA aid has been used to fund ‘specifically religious activit[ies] in an otherwise substantially secular setting.’”[14] Prior to the District Court trial date, the parties in the case entered into a consent decree that required the Department of Health and Human Services (HHS) to monitor programs closely, “including prior approval of all curricula used by religious providers, and restrictions on the presence of religious images or publications in the space used for the program,” in order to ensure that federal funding was not improperly used to promote religious messages.[15] Despite the eventual outcome of the AFLA court case, violations did not stop and lawsuits continue to be filed.
 
Mississippi’s “Abstinence Works! Let’s Talk About It!” Teen Summit
For several years, Mississippi used a portion of its federal abstinence-only-until-marriage funding to sponsor the annual “Abstinence Works!Let’s Talk About It” Teen Summit, gathering roughly 5,000 teens from across the state.The Summit provides participants with a day-long program featuring local celebrities, faith leaders, and public officials as speakers. The 2008 Summit, held on May 17, began with an invocation by a religious leader who asked the participants to bow their heads and “pray in Jesus’ name.”[16] Other speakers made reference to religion, specifically Christianity, including Executive Director of the Department of Human Services (DHS) Don Taylor who, while introducing Lieutenant Governor Phil Bryant, stated that Bryant “was not ashamed of the Gospel of Jesus Christ.”[17] Following the 2008 Summit, the ACLU submitted a letter to the DHS requesting that the 2009 Summit not include religious references; however, the DHS never responded to the letter.
 
Far from refraining from mentioning religion, the 2009 Summit, also paid for with federal funds, again prominently featured references to Christianity. This Summit featured an invocation by Reverend Gary Bell, who also gave the invocation at the 2008 Summit and, similar to his 2008 appearance, prayed in “the precious name” of Jesus Christ.[18] Perhaps the most egregious example of proselytizing at the 2009 Summit came courtesy of Mississippi State Judge John J. Hudson, who quoted biblical scripture and referenced the Ten Commandments while speaking about the importance of abstinence. During his speech, Judge Hudson asked the crowd rhetorically, “Where did these rules of abstinence come from to begin with?” He supplied the answer that “it all begins, as you well know, with our Creator. When he created you and me . . . He looked at us and what did He say, after He created human beings? He said, ‘This is good.’ ‘This is good.’”[19] Judge Hudson then enumerated the Ten Commandments. He related the Seventh Commandment to abstinence from sexual activity: “And then, finally, that rule of abstinence that is most closely associated with what we are here for today . . . ‘Abstain,’ God says, ‘from promiscuous sex—thou shall not commit adultery.’” “But why? Is not God being a killjoy?” the Judge speculated. “Did He not create this great gift which is so good and wonderful? Why would He tell us not to do it? He’s not. He’s telling us that He created this great and wonderful gift for a special and unique committed relationship that is to last forever.”[20] Judge Hudson further said,
 
You see, God knows what is best for us, and what indeed we can look forward to pursue our happy life. . . . Do unto others as you would have them do unto you. And Jesus adds, “Love thy neighbor as you would love yourself.” It’s all wrapped up in that, He says. Is it loving to steal, to lie, to kill, to gossip, to put down, to abuse drugs? No, it’s not. Is it loving to make someone else an object of our sexual pleasure? No, it’s not. So our faith calls us to abstain but it causes us to fill those moments of abstinence with those moments of active love. . . . To honor each other as wonderful creatures and creations of God.
 
Thus, in addition to giving what effectively amounted to a sermon, Judge Hudson equated premarital sexual activity to drug abuse and reduced sexual partners to “objects.” Judge Hudson finally concluded by paraphrasing a benediction given by St. Francis of Assisi.[21]
As a result of this blatant misuse of taxpayer funds to promote religion, the ACLU and its state branch in Mississippi filed suit against the DHS. While the ACLU presented a powerful argument that the DHS had willfully misused federal funds to advance religious beliefs, the lawsuit stalled when the DHS affirmed that it would not sponsor a 2010 Summit.
  
“Stop and Think”
In 2007, the ACLU and its state branch in Oregon alerted the HHS and the Oregon Department of Human Services (OR DHS) to the misuse of federal abstinence-only-until-marriage funding provided by both the Community-Based Abstinence Education (CBAE) program and the Title V abstinence-only-until-marriage program at the Lane Pregnancy Support Center in Oregon and the Northern Hills Pregnancy Care Center in South Dakota. The Lane Center had developed and disseminated an abstinence-only-until-marriage curriculum called “Stop and Think,” which was used by the Northern Hills Center. The contract between Lane and Northern Hills “explicitly require[d] that Northern Hills adhere to Christian beliefs and present the Stop and Think program accordingly.”[22] In addition, presenters of “Stop and Think” at Northern Hills were contractually obligated to
  • possess an authentic relationship with Jesus Christ
  • possess knowledge of the Word of God, and the ability to communicate it’s [sic] truth
  • exhibit a loving and merciful spirit
  • attend a Bible believing local church or fellowship[23]
 Further, applicants to direct the “Stop and Think” program at Northern Hills were asked to submit a “letter of Christian testimony” in addition to a résumé.[24] The ACLU also expressed concern that Northern Hills used federal funds to stage “purity balls” that featured religious content.
 
The OR DHS, which distributed the Title V abstinence-only funding to Lane, responded to the letter from the ACLU by abruptly terminating its contract with Lane. The HHS informed the ACLU that a previous audit had not identified any federally funded proselytizing activities at Lane, but declined to investigate the matter further. Regarding the “purity balls” at Northern Hills, the HHS determined that “Federal dollars were used for a father-daughter event that did not include any religious content,” and that “a separate event with religious content” was held following the ball, but acknowledged that “the separation between these two events could in the future be strengthened.”[25]
 
The “Silver Ring Thing”
In 2006, the ACLU settled a lawsuit filed against the HHS in a case challenging federal funding of religious activities in the “Silver Ring Thing,” an abstinence-only-until-marriage program aimed at young people. From 2003 to 2006, the federal government awarded more than one million dollars to the “Silver Ring Thing.”
 
Prior to the settlement, the “Silver Ring Thing” described its mission as “offering a personal relationship with Jesus Christ as the best way to live a sexually pure life.”[26] During its flagship three-hour program, which took place across the country, members testified about how accepting Jesus Christ improved their lives, quoted Bible passages, and urged audience members to ask the Lord Jesus Christ to come into their lives. Participants then signed a covenant “before God Almighty” to remain virgins.[27] Each young person who successfully completed the program earned a silver ring inscribed with a Bible passage reminding them that, “God wants you to be holy, so you should keep clear of all sexual sin.”[28]
 
As a result of the lawsuit, HHS agreed that it would not fund the abstinence-only-until-marriage program as it was structured, and that any future funding for the “Silver Ring Thing” would be contingent on the group’s compliance with federal law prohibiting the use of federal funds to support religious activities. In addition, HHS agreed to closely monitor any future grants to the program until September 30, 2008.
 
The "Louisiana Governor’s Program on Abstinence”
In 2002, the ACLU filed a lawsuit challenging the use of taxpayer dollars to fund religion in the “Louisiana Governor’s Program on Abstinence” (GPA). The ACLU demonstrated that the governor’s program had granted hundreds of thousands of dollars to programs that used the funds to support religious activities and promote religious messages. Among the cited examples were programs that
  • presented “Christ-centered” theater skits
  • held a religious youth revival
  • produced radio shows that “share abstinence as part of the gospel message”[29]
In 2002, a federal district court found that GPA funds were being used to convey religious messages and advance religion, in violation of the Constitution’s requirement of separation of church and state, and ordered Louisiana officials to stop this misuse of taxpayer dollars. Although the GPA agreed to stop using public money to “convey religious messages and otherwise promote religion” in any way and to closely monitor the activities of all grantees, the ACLU found that the governor’s program continued to feature religious materials on its official website, the now defunct www.AbstinenceEdu.com, until 2005. State-appointed experts advised readers, for example, that
  • Abstaining from sex until entering a loving marriage will . . . [make you] really, truly, “cool” in God’s eyes.
  • God chooses this one sin [sex outside of marriage] above all others as the most destructive to your soul and spirit.[30]
Despite lawsuits like these, many abstinence-only-until-marriage programs have continued to use federal funds to promote religious-based viewpoints and practices. This is in direct violation of the U.S. Constitution.
 
Violate U.S. State Constitutional Guarantees
 
Many state constitutions include positive rights to health and to adequate education that parallel international human rights standards. These provisions create affirmative state obligations to protect the public health and provide an adequate education to state residents. While no litigation has yet challenged abstinence-only-until-marriage curricula and programs on these grounds, state and local government programs that use federal and/or state funds to jeopardize the public health by providing inaccurate, incomplete, and biased health and sexuality education clearly violate the spirit of these state constitutional guarantees.
 
These provisions may provide yet another route through which advocates can work to curtail the continued support for abstinence-only-until-marriage programs.
 
Updated November 2010
 


[1] National HIV/AIDS Strategy for the United States (Washington, DC: Office of National AIDS Policy, 2010), accessed 13 July 2010, <http://www.whitehouse.gov/sites/default/files/uploads/NHAS.pdf>, iii.
[2] Ibid., 20.
[3] International Covenant on Civil and Political Rights, G.A. res. 2200A (XXI), 21 U.N. GAOR Supp (No. 16) at 52, U.N. Doc. A/6316 (1966), accessed 20 August 2010, <http://untreaty.un.org/English/millennium/law/human_rights/iv_4E.wpd>, article 19.
[4] Programme of Action of the International Conference on Population and Development,Cairo, 5–13 September 1994, U.N. Doc.A/CONF.171/13/Rev.1 (1995), accessed 26 August 2010, <http://www.un.org/popin/icpd/conference/offeng/poa.html>, para. 7.41.
[5] Convention on the Rights of the Child, G.A. res. 44/25, annex, 44 U.N. GAOR Supp. (No. 49) at 167, U.N. Doc. A/44/49 (1989), accessed 20 August 2010, <http://www2.ohchr.org/english/law/crc.htm>, article 24(2)(e).
[6] General Assembly Special Session on HIV/AIDS, Declaration of Commitment on HIV/AIDS, G.A. res. S-26/2 (2001), accessed 21 October 2010, <http://www.un.org/ga/aids/docs/aress262.pdf>.
[7] Committee on the Elimination of Discrimination against Women, General Recommendation No. 24 (20th session, 1999), accessed 20 August 2010, <http://www.un.org/womenwatch/daw/cedaw/text/econvention.htm>, article 5(a).
[8] Berlin Call to Action, Berlin, 2–4 September 2009, accessed 20 August 2010, <http://www.globalngoforum.de/fileadmin/templates/downloads_outcomedocuments/NGO%20Forum%20CfA%20englisch.pdf>, 1.
[9] Office of the United Nations High Commissioner for Human Rights and the Joint United Nations Programme on HIV/AIDS, HIV/AIDS and Human Rights-International Guidelines (from the second international consultation on HIV/AIDS and human rights, 23–25 September 1996, Geneva), U.N. Doc. HR/PUB/98/1, Geneva, 1998, accessed 20 August 2010, <http://data.unaids.org/publications/IRC-pub03/hright2_en.pdf>, para. 30(h).
[10] John Santelli et al., “Abstinence and abstinence-only education: A review of U.S. policies and programs, Journal of Adolescent Health 38.1 (June 2006), accessed 21 October 2010, <http://download.journals.elsevierhealth.com/pdfs/journals/1054-139X/PIIS1054139X05004672.pdf>, 78.
[11] Ibid.
[12] Ibid.
[13] Bowen v. Hardwick, 487 U.S. 589, 622 (1988) (O’Connor, J. concurring.)
[14] Ibid., 621.
[15] Ira C. Lupu and Robert W. Tuttle, “Roundtable Legal Update—ACLU of Massachusetts v. Leavitt, U.S. District Court, District of Massachusetts,” Roundtable on Religion and Social Welfare Policy (7 March 2006), accessed 20 October 2010, <http://www.religionandsocialpolicy.org/legal/legal_update_display.cfm?id=44#18>.
[16] “Complaint,” Robinson v. Thompson, Civil Action No. 3:09C0537WHB-LRA, U.S. District Court for the Southern District of Mississippi, filed 9 September 2009, accessed 26 August 2010, <http://www.aclu.org/files/pdfs/reproductiverights/robinsonvthompson_complaint.pdf>, 6.
[17] Ibid., 7.
[18] Ibid., 9.
[19] Ibid. 10­­–11; see also Kate Royals, “God and Abstinence,” Huffington Post, 9 June 2009, accessed 2 November 2009, http://www.huffingtonpost.com/sexual-justice/god-and-abstinence_b_213462.html, for video excerpts of the 2009 “Abstinence Works! Let’s Talk About It!” Teen Summit, produced by Stuart Productions.
[20] Ibid.
[21] Ibid.
[22] Letter from ACLU Reproductive Freedom Project to Secretary of Health and Human Services Michael Leavitt, 2 May 2007, accessed 20 August 2010, <http://www.aclu.org/files/images/asset_upload_file14_29585.pdf>, 2.
[23] Ibid.
[24] Ibid., 3.
[25] Letter from Acting Assistant Secretary for Children and Families Daniel C. Schneider to ACLU Senior Staff Attorney Julie Sternberg, 12 July 2007, accessed 20 August 2010, <http://www.aclu.org/files/images/asset_upload_file475_30914.pdf>, 1.
[26]American Civil Liberties Union, “ACLU Announces Settlement in Challenge to Government-Funded Religion in the Abstinence-Only-Until-Marriage Program the ‘Silver Ring Thing,’” Press Release published 23 February 2006, accessed 26 August 2010, <http://www.aclu.org/reproductiverights/sexed/
24246prs20060223.html
>.
[27] “Complaint,” ACLU of Massachusetts v. Leavitt, Civil Action No. 05-11000, U.S. District Court for the District of Massachusetts, filed 16 May 2005, accessed 26 August 2010, <http://www.aclu.org/files/FilesPDFs/teeneducomplaint.pdf>, 9.
[28] Ibid.
[29] “Memorandum of Law in Support of Preliminary Injunction,” ACLU of Louisiana v. Foster, Civil Action No. 02–1440, U.S. District Court for the Eastern District of Louisiana, filed 9 May 2002, accessed 26 August 2010, <http://www.aclu.org/files/FilesPDFs/foster.pdf>, 22, 4.
[30] American Civil Liberties Union, “ACLU Troubled by Court’s Refusal to Hold Louisiana Governor’s Program on Abstinence in Contempt for Continuing to Preach with Taxpayer Dollars,” Press Release published 24 June 2005, accessed 26 August 2010, <http://www.aclu.org/reproductive-freedom/aclu-troubled-courts-refusal-hold-louisiana-governors-program-abstinence-contem?tab=press>.