- Procreation is a fundamental right.
- The act of sterilization permanently deprives citizens of this right.
- Sterilization is not narrowly tailored enough to the governmental interest of promoting lawful behavior.
- Infringements on fundamental rights may be addressed as either Equal Protection Clause violations or Substantive Due Process Violations.
- State action abridges everyone's fundamental right: Substantive Due Process
- State action abridges a certain class's fundamental right: Equal Protection Clause