(1) Same Sex Marriage & Custody
Same sex divorce cases will no doubt be litigated with greater frequency after the United States Supreme Court’s decision granting the right of same sex couples to marry in Obergefell. Where a same sex couple is married and divorcing, and the child is born during the marriage, custody cases between same sex couples are presumably to be resolved using the “established legal framework applicable to married couples.” In terms of same sex couples who are not married, there is a question about whether a same sex partner who is not a biological parent can gain any custody rights. In 2015, the Missouri Court of Appeals for the Western District issued an important decision on this topic in McGaw v. McGaw.
In McGaw, appellant, Melissa McGaw (“Melissa”) filed a motion to determine the parent-child relationship, custody, and visitation rights with respect to the two children for which she was not biologically related. The children involved in this case were born at a time when Melissa was involved in a romantic relationship with the children’s biological mother, Angela McGaw (“Angela”). The Western District notes that the McGaws’ relationship began, and ended, at a time when the right of same sex couples to marry was not recognized in Missouri.
Despite their inability to marry, Melissa’s motion alleges that she and Angela took multiple steps to formalize their relationship. For example, they participated in a commitment ceremony, changed Angela’s surname to match Melissa’s, purchased a home together, jointly chose to conceive the children and raise them together, as well as enter into an agreement that governed the termination of their relationship.
However, Melissa and Angela were never married. For this reason, the Western District ultimately decides this case under the legal rules applicable to unmarried couples. Following the decision of the Supreme Court of the United States in Obergefell v. Hodges, the Western District notes that couples like Melissa and Angela are now able to marry if they choose. The Western District also points out that cases like this one, in which important issues involving children must be decided outside the established legal framework applicable to married couples, will be rare in the future.
On appeal, Melissa does not challenge the circuit court’s dismissal of her claim to have parentage established under the Missouri Uniform Parent Act. Instead, she argues that she states a claim for relief based on the theories of breach of contract or under common law equitable doctrines. The Western District notes that none of these theories justify reversal.
According to the Western District, now that same sex couples have the right to wed, litigants like Melissa will not have to focus on the alternative claims such as breach of contract or common law equitable doctrines if they are married. Instead, any and all laws that were applicable to married heterosexual couples are now going to be applicable to married homosexual couples. The Western District also points out that the proper remedy for Melissa is a third party custody by stating:
Under T.Q.L., Melissa has the right to assert her claims for child custody and visitation in an independent proceeding under § 452.375.5(5); indeed, in her briefing Melissa states that she has filed a separate petition for third-party custody under the statute concurrently with this appeal. The availability of a cause of action under § 452.375.5(5) further diminishes the need to adopt the non-statutory equitable parentage doctrine in this case.
For a same sex partner who is not a biological parent, and who is not married, this decision may not lead to a desired result if the individual cannot make a claim for third party custody. Nonetheless, this is an important case in Missouri on this topic because it shows the difficulties that an unmarried, same sex partner is likely to face if they are not a biological parent. As the decision points out, however, there may be circumstances where an unmarried, same sex partner may seek custodial rights by filing a petition for third party custody.
(2) Essential Information About ART
Alternative reproductive technologies (hereinafter referred to as “ART”) can also present some challenges and complexities in family law. There are multiple forms of ART, including surrogates, gestational carriers, in vitro fertilization (hereinafter referred to as, “IVF”), intrauterine insemination, sperm donation, and egg donation. The most common of these methods is IVF. This procedure is when the eggs are extracted from the donor, and then combined with sperm in a laboratory. Later, the pre-embryos are either cryopreserved or implanted into the uterus.
In the context of lesbian couples, one or both persons can go through IVF. In some cases, the egg may be extracted from one partner, and the pre-embryos implanted into the other, making the latter the gestational carrier. For same sex couples, it is common to use traditional methods such as a surrogate or a gestational carrier. In these agreements, the surrogates will surrender any parental rights after birth. The premises provided thus far sound fairly simple, but we will come to discover that numerous complexities can arise in almost all facets of the pre-embryo or child’s life.
(3) Rights of Children Born From Embryos
There is an ethical conundrum that can arise when dealing with the rights of children born from frozen embryos. On one hand, there is the biological parent’s interest in retaining their anonymity regarding the donation they have made to give life to a child. On the other hand, there is also a strong argument that the child should have the right to know the identity of their biological parents.
The right to inheritance can also arise. In Seaman v. Colvin, the mother, individually and as guardian on behalf of her minor children who were born using ART, sought review of a decision denying her application for the child’s survivor insurance benefits on behalf of their deceased wage earner. The father previously had his sperm cryopreserved, but later died of Hodgkin’s Lymphoma. The court states that the children who were born by means of ART after the death of their father were not entitled to inherit by intestate succession from the deceased father’s estate and, thus, were not qualified “children” of an insured individual under the Social Security Act.
(4) Disposition of Frozen Embryos in Divorce
There are an amazing number of people that are born through the use of ARTs. Approximately 1.5% of all infants born are conceived using ARTs. When couples or individuals participate in ARTs, and they subsequently create embryos, there are often more pre-embryos created than are necessary to conceive a child. This gives rise to the issue of what to do with the extra pre-embryos. There are existing options for the dispositions of embryos, and these options arise out of divorce cases, when the parties disagree over their use, or lack thereof:
(a) Use by one of the parties for reproductive purposes;
(b) Donation (either to research or to other intended parties for reproductive purposes); or
When analyzing what the courts should do with cryopreserved pre-embryos in divorce cases, a couple questions arise that the court usually has to address. First, are the embryos “children of the marriage” such that custody and control of them is determined on the basis of a “best interest” analysis? Second, are the embryos martial property such that they should be disposed of in a property settlement pursuant to the principles of equitable distribution? This is the standard that you will see most courts use to analyze this issue.
Additionally, courts are often faced with the issue of weighing the interests of the parties. The interests that are usually weighed are the interests and rights to procreate. This interests and right creates an opposite right to not procreate, or to avoid parentage, so the courts are normally stuck between balancing the two. There is also a big question that arises when using ARTs and the role of pre-conception and IVF forms. We will discuss all of the answers and arguments relevant to these questions below.
One of the earliest cases concerning disposition of frozen embryos and discussing the issue of whether pre-embryos are considered human beings or property is Davis v. Davis. In Davis, the court was asked which member of the divorcing couple should control the disposition of the pre-embryos. The court discusses the limitation of conditions to which the embryos would be able to be discarded if they were found to be legal persons. They found that, because of repercussions of defining embryos as legal persons, they “are accorded more respect that mere human cells because of their burgeoning potential for life.” They rejected the proposition of defining cells as legal persons because “even after viability, they are not given legal status equivalent to that of a person already born.”
Presently, there is little uniformity across that country as to the allocation of frozen embryos in a divorce. However, there are three distinct analytical approaches. The first of those approaches is a contractual analysis. This analysis consists of a strict contractual approach, which enforces the terms of the directive or agreement with the clinic as to what happens to the embryos upon specified circumstances such as death or divorce.
The second main approach is the mutual consent approach. The contemporaneous mutual consent model holds that absent joint consent, the embryos are kept in a cryopreserved state. If either party has a change of heart, advance directives are disregarded and the party’s current objection takes precedence.
The third approach is the balancing approach. In this analysis, there is a balancing of interest based upon the parties’ interests in the preservation or destruction of the embryos, their relative positions, and the burdens being imposed on both depending on the outcome.
There are certain cases that allow the disposition of the embryos to be governed by a time frame prescribed by a cryopreservation agreement. In Litowitz v. Litowitz, a couple had two embryos formed with donor eggs, and the husband’s sperm, after a successful birth using a surrogate. The couple had the leftover eggs frozen with the intention that they would someday be implanted in the uterus of a surrogate mother, but the couple subsequently divorced. The husband wished to place any children born from the embryos up for adoption in a two-parent family outside the state of Washington but the wife appealed from the court’s ruling because she wanted to raise any potential children. The Washington Supreme Court ruled that the pre-embryos should be thawed out and allowed to expire because the dispute had not been resolved within a five-year timeframe prescribed by the Cryopreservation Agreement. There is an emerging trend to enforce the clinic consent forms that parties sign, or other relative agreements between them, while giving the parties the option of mutually modifying the agreement later. If there is no agreement, the court goes to a balancing analysis. The right not to procreate general prevails, with exceptions of course. If the party who wants to use the embryos for procreation purposes has no other means of having a genetically related child, the courts may consider awarding the embryos to that party over the other party’s objection.
A case demonstrating the contract approach is Kass v. Kass. In Kass, a husband and wife underwent IVF, which resulted in five surplus embryos for storage. The husband and wife signed consent forms at the clinic prior to treatment stating that in the event of a divorce, the embryos would be disposed of by the clinic or used for research. The couple subsequently divorced and signed an agreement that said that the stored embryos would be handled in a manner consistent with the clinic consent form. Later, the wife sought custody of the embryos on the basis that this was her only chance at genetic parenthood. The court enforced the terms of the consent forms, looking to the original intent of the parties and honoring those intentions.
A case that is distinguished from Kass is A.Z. v. B.Z. In A.Z. v. B.Z., the court rejects enforcement of agreements under public policy reasoning where a husband and wife underwent IVF treatments, which resulted in the birth of twin girls. The couple later separated, and the wife implanted left over embryos without the husband’s knowledge and consent. The court looked at the forms (which the husband only signed one of the seven consent forms) that said in the event of a divorce, the embryos should be returned to the wife for implantation. The court said that the conduct of the couple surrounding of the execution of the consent form(s) created doubt on the parties’ true intent.
A case demonstrating the mutual consent model is In re Marriage of Witten. In the context of divorce proceedings, the wife sought control of the frozen embryos so that she could bear a genetically linked child. The husband sought a permanent injunction prohibiting either party from unilaterally utilizing the embryos without written consent from the other. The lower court ruled that agreements entered into at the clinic are enforceable and binding, subject to the right of either party to change their mind regarding the disposition of the embryos. The higher court affirmed the trial court’s ruling stating that neither party could transfer, release, or use the embryos without the other’s written consent.
The third approach, the balancing approach, in best demonstrated in Reber v. Reiss. In Reber, the Pennsylvania Superior Court upheld the trial court’s use of the balancing approach to award frozen embryos to the wife in divorce proceedings. Upon commencing their ART procedures, the spouses had signed consent forms at the clinic, which said that the embryos would be destroyed after three years. The wife at trial testified that the embryos were her only reasonable chance to procreate after surviving cancer treatments that rendered her infertile, and promised to use all reasonable efforts to support the child without any financial assistance from the husband. The husband argued that he did not wish to have a child with his ex-wife or to incur the financial obligation of an unintended child. The court affirmed the lower court’s refusal to enforce the destruction provision in the consent form signed by the spouses, and held instead that the balancing of interests tipped in the wife’s favor.
Another case that demonstrates the balancing approach is J.B. v. M.B. In this case, the court weighed the wife’s right not to procreate against the husband’s interest in using or donating the remaining pre-embryos. The court found that the wife’s interest to not procreate outweighed the husband’s interests because the father was still able to father other children on his own.
Courts have also applied a hybrid analysis that combines the contractual and balancing approach. In Szafranksi v. Dunston, there was a couple that was dating, with no evidence of any long-term prospect. She was diagnosed with non-Hodgkin’s Lymphoma and was told that her chemo treatments would likely render her infertile. Their IVF physician advised her to undergo IVF prior to chemo to create embryos that would be stored until after treatment. They also signed an agreement to provide sperm to use in conjunction with the eggs to create embryos. The agreement stated the following:
Because of the possibility of you and/or your partner’s separation, divorce, death or mental incapacitation, it is important, if you choose to cryopreserve your embryos, for you to decide what should be done with any of your cryopreserved embryos that remain in the laboratory in such an eventuality […] Embryos are understood to be your property, with rights of survivorship. No use can be made of these embryos without the consent of both partners (if applicable) […] In the event of divorce or dissolution of the marriage or partnership, [the clinic] will abide by the terms of the court decree or settlement agreement regarding the ownership and/or other rights to the embryos.
The couple created three embryos, but they subsequently broke up and Jacob later filed a lawsuit seeking to enjoin Karla from using the embryos. Karla counterclaimed seeking sole custody and control. The court affirmed the lower court’s ruling that Karla was entitled to sole custody of the embryos under both a contract and balancing analysis. The evidence of assent from Jacob from a phone conversation created an oral contract between the two. The court further stated that the parties did not modify their oral contract when they signed the informed consent at the clinic because the document contemplated the parties reaching a separate agreement. The court ultimately honored the parties’ original intent as set forth in the prior agreement.
The Szanfranksi case is distinguishable from most other decisions with similar facts because those couples that signed the forms were married and subsequently divorced. In this case, this was just an unmarried couple. The court also found in that case that the lower court did not err in finding that her interests should prevail based on the fact that it is her only possible chance at genetic parenthood.
What does the case law from these three approaches mean in the context of same-sex marriages? Theoretically, it should not mean much following the Obergefell decision. The right to marry was deemed fundamental, and under Due Process and Equal Protection, same-sex couples cannot be deprived the right to marry. Prior to Obergefell, the Supreme Court ruled in United States v. Windsor that §3 of the Defense of Marriage Act violated the 5 th Amendment. This ruling recognized same-sex couples, and it changes the language of thousands of federal regulations in order for them to apply to same-sex couples. With the Obergefell decision as controlling authority, all cases in the past that have dealt with same-sex couples and ARTs no longer pose the complexities that they once did. Cases like the ones discussed earlier in the context of the three approaches to disposition of frozen embryos will now apply to same-sex couples.
In Missouri, there is a 2015 case that has gained nationwide publicity for the uniqueness of the contested divorce proceedings. Jalesia “Jasha” McQueen-Gadberry and Justin Gadberry have been going through divorce proceedings for the past five, going on six, years – mostly concerning the disposition of the cryopreserved embryos that they created together. McQueen and Gadberry created the embryos in 2007, where they had two of the four successfully fertilized embryos implanted. The remaining two pre-embryos remain cryopreserved. Prior to going through IVF treatments, the then couple signed an agreement with the fertility clinic that McQueen would receive the embryos in the event of a divorce. McQueen and Gadberry differed in opinions with regards to what should be done with the embryos in that he wanted them to be donated to an infertile couple, donated to research, or to be destroyed.
In the amicus curiae brief supporting McQueen in her appeal of the trial court’s decision, the Thomas More Law Center argues that the trial court failed to recognize the embryos as human beings. It is contends that under RSMo. § 452.705, embryos should be protected because they are minor children. Furthermore, they assert that RSMo. § 452.705 should be construed in the light and context of RSMo § 1.205, which states that, “1. The general assembly of this state finds that: (1) The life of each human being begins at conception; (2) Unborn children have protectable interests in life, health, and well-being; (3) The natural parents of unborn children have protectable interests in life, health, and well being of their unborn child. [2. Omitted] 3. As used in this section, the term ‘unborn children’ or ‘unborn child’ shall include all unborn child or children or the offspring of human beings from the moment of conception until birth at every state of biological development.” In defining conception, the brief supporting McQueen states that all Missouri statutes should be construed with the understanding that life begins at conception. Moreover, she argues that conception is defined as fertilization of the ovum of a female by the sperm of a man.
Arguing that the embryos are considered protected human beings at the time of conception, and a child under the age of eighteen, according to RSMo §1.205 and RSMo §452.705 respectively, the argument was that embryos in divorce should be subject to a ‘best interests’ analysis, and not simply a division of property.
The brief also argues that the State has a compelling interest in protecting an unborn child that overrides the right of the mother to abort [or discard] her child. But once Roe is brought up, the question arises – at what point is the fetus [or embryo] viable? Planned Parenthood contemplated the technological advance and other medical advances that may occur in the future stating that society will, “continue to explore the matter.” Under Missouri law, the amicus curiae brief argues, an embryo is viable even though it requires artificial aid to sustain viability outside the womb.
The last contention of the brief is that there is no forced procreation if the mother uses the embryos to procreate, which many of the cases we previously discussed relied upon in the decisions. The rationale relies on the fact that the embryos are already considered children past the point of conception.
In McQueen’s brief, there were similar, but additional arguments made to support her position. In a prior Missouri court proceeding, McQueen had a guardian ad litem appointed to the two cryopreserved embryos. The court appoints a guardian ad litem, which can only be appointed in cases where the best interests of a child are being investigated and the trial court recognized this, but later reversed its rationale and ruled that the embryonic cells are inanimate objects. McQueen further contends that in other areas of the law, unborn children have protections and recognition of being human beings for legal purposes – they are recognized in wrongful death statutes, manslaughter statutes, as well as murder statutes.
Another argument that McQueen presents in her brief is that the trial court gave the father the unprecedented right to direct the death of embryonic children. Historically, the courts have given the pregnant woman the right to choose to bring a baby to term even over the father’s objections. Some might argue whether McQueen may have her cake and eat it, too? This argument and past arguments perhaps conflict with abortion jurisdiction. This argument arguably falls apart because on one hand, abortion jurisdiction does apply, and on the other, it does not. In the amicus curiae brief by the Thomas More Law Center, it is argues that abortion jurisdiction does not apply because the embryos are outside the womb. They further argue that applying RSMo § 1.205 to RSMo §452.705 does not require any child to term, but rather it allows for the opportunity to do so. If abortion jurisdiction does not apply, then should mother’s rights to direct the disposition of the embryonic cells still trump father’s rights?
The latter argument seems to be perplexing to some, but the former seems to have a valid point of contention from the standpoint of expansive interpretation of statutory language. The point of contention could potentially dissipate if McQueen and other Missouri state legislators pass a bill modifying the language of child custody statutes. The effort seeks to define embryos as human life as opposed to property that is divided like personal effects and other tangible, household items. According to Carla Hoste, a family law practitioner, expanding the language could have catastrophic consequences – do IVF clinics or anyone who discards embryos subject to manslaughter or murder charges? Sarah Ross of the ACLU states that this would violate people’s 14 th Amendment right to not procreate, because the new definition would force someone to become a parent in all circumstances. The goal with changing the language is to apply a best interests approach to custody cases involving embryos.
This issue of defining the embryo as property or persons has arisen in the past. The embryos are a special type of property, somewhere in the gray area between property and personhood. Embryos are unlike any other property because if one parent wants to use them, the other would never truly be separated from that property due to child support payments and other obligations that arise out of parenthood.
In November of 2016, the Eastern District of the Missouri Court of Appeals published its opinion regarding McQueen’s appeal on the grounds that the trial court mischaracterized the cryopreserved pre-embryos as marital property of special character. The appellate court states in their opinion that the lower court did not err in that regard, because the pre-embryos are in vitro, and therefore both the parties are considered to have equal interest in them.
Accordingly, McQueen’s right to procreate would not be irrevocably extinguished by denying her the exclusive right to the embryos, whereas, Gadberry’s interest in his right not to procreate with McQueen would be irrevocably extinguished if she was granted the exclusive use of the pre-embryos. The court stated, “although McQueen has the right to procreate, that does not mean that she has the right to procreate with Gadberry by implanting the frozen pre-embryos which contain his genetic material.”
Additionally, McQueen made the argument that the embryos should be considered human life under the interpretation of Missouri Statutes and the legislative intent, but the court finds that the statutes historically had only referred to human life as in utero and inapplicable to the circumstances of this case.
A similar case arose out of California recently. Mimi Lee, the intended mother, wanted to use the embryos created with her husband after she lost her fertility due to cancer treatments. The IVF consent form that the couple signed states that in the event of divorce, the embryos should be destroyed. Lee argues that the IVF consent form is not legally binding and that this is her last chance at biological parenthood, in an effort to try and compel the court to rule in her favor. The court finds that Lee does have the right to procreate, just not with her ex-husband.
This is a little deviation from other court cases that are discussed previously where the court grants the embryos to the mother who has no other chance of biological parenthood. The twist of not being able to procreate with the other party in question seems to strike a balance in theory (respecting the right not to procreate of the husband and recognizing the right to procreation of the mother), but not practically.
There have been around eleven cases since 1992 concerning the disposition of frozen embryos in divorce. Eight out of the eleven of those cases, the judge rules in favor of the partner who asserts their right not to procreate. States like Pennsylvania, Illinois, and Maryland are the only three states that have sided with the woman where it is their last chance of biological parenthood.
(5) Whether Sperm Donors Could Have Child Support Obligations
Perhaps the most publicized case of a sperm donor having to pay child support arises out of Kansas. William Marotta, who responded to a lesbian couple’s Craigslist ad for supplying sperm to help the lesbian couple give birth to and raise a child, was forced to pay child support. The donor and the couple signed agreements prior to their ‘at home’ artificial insemination stating that the donor would not be held responsible for child support, or any other obligations that may arise.
Under Kansas law, Marotta would not have been held liable for child support if a physician had carried out the procedure. The state licensed physician participation would have rendered him officially a sperm donor, and therefore not liable for child support payments. The concern in having a physician participate in these procedures is one of public policy – it is important to make sure that the donor is screened for any genetic defects such as diseases that can be passed down through inherited genetic material. Importantly, Missouri essentially has the same language as Kansas in RSMo. § 210.824.2:
The donor of semen provided to a licensed physician for use in artificial insemination of a married woman other than the donor’s wife is treated in law as if he were not the natural father of a child thereby conceived.
Conversely, there are cases that demonstrate that agreements prior to artificial insemination can be enforced. In Ferguson v. McKiernan, the court enforced the agreement between the sperm donor and donee, that the donor would not be held responsible for child support payments. The sperm donor in this case argued that there is public policy precluding parents from bargaining away a child’s rights to child support should not preclude an otherwise binding contract between the parties. He contests that but for the promise to seek child support, the donor would have never participated. The sperm donor also cites §702 of the UPA which states that, “a donor is not a parent of a child conceived by means of assisted reproduction,” and “the donor can neither sue to establish parental rights, nor be sued and required to support the resulting child. The mother in this case argues that the “best interests” approach should be applied in this case. Furthermore, she urges that the interests of the child preclude the enforcement of the contract upon the parties. The court ultimately rules in favor of the sperm donor.
In Mintz v. Zoernig, the biological mother of a child was artificially inseminated, and moved against the sperm donor for child support. The artificial insemination that took place in this case was not done so through a licensed physician, which consequently, does not allow the sperm donor to fall under the exception under the UPA. The sperm donor’s contention was that he was merely a sperm donor, but the court found otherwise. The court held that the sperm donor was the father, and therefore obligated to pay child support because the father had done numerous things to lead to such conclusion, including:
- The sperm donor held himself out to be the children’s father;
- He has had a relationship with the children since their birth;
- He has enjoyed visitation with each child;
- The sperm donor has acknowledged that he is the natural father of each child; and
- He is registered as both of the children’s father with the Vital Statistics Bureau.
Three months after the Mintz decision, another court looked at a similar case of a known sperm donor. In Jacob v. Shultz-Jacob, a sperm donor provided genetic material to a lesbian woman. In short, the court found that the man was automatically recognized as the possessor of parental rights [and obligations] based on his biological parenthood.
The stories of sperm donors being held liable for child support tend to grab the attention of the local media outlets. Another story, from the New York Post, discusses a sperm donor who had been sending gifts to his biological son signed “Dad.” Eighteen years prior, the man had helped his friend get pregnant by donating his sperm. When his son approached the age of 18, the biological mother came after the father for child support, and won. The court said that the father had put himself out there as the child’s dad, and had developed a relationship with the child, at least enough to force a child support payment for the 18 years he had been financially absent from the child’s life.
We can see that the law is less clear about parental status of a known donor, but generally, where the donor is anonymous, the donor is not a legal parent on the hook for child support. Courts have ruled on known sperm donors’ obligations to pay child support using numerous rationales, providing freedom from or obligations to pay child support depending upon the specific facts. But the specific take away is that there is a trend that shows that donors who develop a relationship with the child(ren) drastically increase the likelihood that the court will find that the man is responsible for child support. Where sperm is not provided to a licensed physician for insemination, the risk is also high that a court will enter a child support order.
A couple of other case examples are also instructive on this topic. In the case of In re Baby Doe, the Supreme Court of South Carolina held that a husband who consents for his wife to conceive a child through artificial insemination, with the understanding that the child will be treated as his own, is the legal father of the child born as a result of the artificial insemination and will be charged with all the legal responsibilities of paternity, including support.
Similarly, in the case In re Marriage of A.C.H. & D.R.H., the Court of Appeals of Oregon held that a husband consented to and participated in the artificial insemination of his wife, and thus husband was the father of the child that resulted and was required to pay child support for the child.
McGaw v. McGaw, 468 S.W.3d 435, 438 (Mo. App. W.D. 2015) (stating that after the decision of the Supreme Court of the United States in Obergfell v. Hodges, issues involving children can be decided using established framework applicable to married couples.)
Assisted Reproductive Technology (ART), National Institute of Child Health and Human Development, https://www.nichd.nih.gov/health/topics/infertility/conditioninfo/Pages/art.aspx (last visited December 24, 2016).
Lindsey Zalvidar, Types of Assisted Reproductive Technology (ART), ConceiveEasy, http://www.conceiveeasy.com/get-pregnant/types-of-assisted-reproductive-technologies-art/ (last visited December 24, 2016).
Travis Zimpfer, In Vitro Fertilization Bill Would Define Embryos as Human Life, March 15 th, 2016, The Missouri Times. https://www.themissouritimes.com/277760in-vitro-fertilization-bill-would-define-embryos-as-human-life/. (last accessed on July 7 th, 2016).