Note:
David S. Coale, Norplant Bonuses and the Unconstitutional Conditions Doctrine, 71 TEXAS L. REV. 189 (1992).
 

Abstract:
A number of states have enacted programs to pay bonuses to women who accept the Norplant contraceptive device. This Note claims that these bonuses, by penalizing women who do not accept the device, are a prime example of the “unconstitutional conditions” doctrine. The Constitution gives women a right against forced contraception. Therefore, making payment of benefits conditional upon acceptance of a contraceptive device is an unconstitutional condition.