On 29 June 1988, in Bowen v. Kendrick, the US Supreme Court ruled in a five-to-four decision that the 1981 Adolescent Family Life Act, or AFLA, was constitutional. Under AFLA, the US government could distribute federal funding for abstinence-only sexual education programs, oftentimes given to groups with religious affiliations. As a federal taxpayer, Chan Kendrick challenged the constitutionality of AFLA, claiming it violated the separation of church and state. The Supreme Court found that although AFLA funded programs that aligned with certain religious ideologies, it was constitutional because it did not encourage government involvement in religion, and it held a valid secular purpose in seeking to prevent adolescent pregnancy and premarital sexual relations. By upholding AFLA, Bowen v. Kendrick enabled the US government to continue funding abstinence-only education, which researchers have found to be ineffective.

In 2007, Françoise Baylis and Jason Scott Robert published “Part-Human Chimeras: Worrying the Facts, Probing the Ethics” in The American Journal of Bioethics. Within their article, hereafter “Part-Human Chimeras,” the authors offer corrections on “Thinking About the Human Neuron Mouse,” a report published in The American Journal of Bioethics in 2007 by Henry Greely, Mildred K. Cho, Linda F. Hogle, and Debra M. Satz, which discussed the debate on the ethics of creating part-human chimeras. Chimeras are organisms that contain two or more genetically distinct cell lines. Both publications discuss chimeras with DNA from different species, specifically in response to studies in which scientists injected human brain cells into mice. “Part-Human Chimeras,” contributes to a chain of ethical and scientific discussion that occurred in the mid-2000s on whether people should be able to conduct research on chimeras, especially in embryos.

In 2006, bioethicist Jason Scott Robert published “The Science and Ethics of Making Part-Human Animals in Stem Cell Biology” in The FASEB Journal. There, he reviews the scientific and ethical justifications and restrictions on creating part-human animals. Robert describes part-human animals, otherwise known as chimeras, as those resulting from the intentional combination of human and nonhuman cells, tissues, or organs at any stage of development. He specifically criticizes restrictions against creating part-human animals made by the National Academy of Sciences, or NAS, in 2005, arguing that while they ensure that such research is morally justifiable, they might limit scientists from conducting useful science using part-human animals or entities. Robert challenges the moral rationales behind prohibiting chimera research, arguing that they may impede scientists from conducting research that could have important benefits to biology and medicine, and suggests how to balance the conflicting moral and scientific needs of such science.