The Michigan Legislature passed a bill in 1913 authorizing sterilization of mentally impaired persons confined in public institutions, even over the objections of a parent or guardian. The law was adopted to prevent those so confined from ever having children.
The largest such institution in the state was the Michigan Home and Training School in Lapeer, whose superintendent sought to sterilize a patient under the new law. The patient's guardian objected, contending that the law was unconstitutional. Lapeer County Circuit Judge William B. Williams agreed, stating that the law, limited only to those confined in public institutions, "so limits the class of feeble minded persons who may be brought within its provision as to almost entirely subvert its object and make it clearly class legislation," and therefore unconstitutional.
The Michigan Supreme Court upheld Judge Williams in 1918 in Haynes v. Lapeer Circuit Judge, questioning why such legislation should fall only upon those "already under public restraint," while mentally impaired individuals in private care or at home were exempt from the law. Such a distinction was found to be discriminatory class legislation violating the equal protection provision of the United States Constitution.
The Haynes decision demonstrates the power of the Constitution
of the United States to protect even the most vulnerable members of our society.