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.

Published in 2002, prostate cancer researcher John R. Masters authored a review article HeLa Cells 50 Years On: The Good, The Bad, and The Ugly that described the historical and contemporary context of the HeLa cell line in research in Nature Reviews Cancer. The HeLa cell line was one of the first documented immortal cell lines, isolated from cervical cancer patient Henrietta Lacks in 1951 at The Johns Hopkins Hospital in Baltimore, Maryland. An immortal cell line is a cluster of cells that continuously multiply on their own outside of the original host. Though the HeLa cell line has contributed to many biomedical research advancements such as the polio vaccine, its usage in research has been controversial for many reasons, including that Lacks was a Black woman who did not knowingly donate her cells to science. In the article “HeLa Cells 50 Years On: The Good, The Bad, and The Ugly,” Masters describes that, despite the benefits of the HeLa cell line, it has caused significant negative impacts on research due to its propensity to contaminate other cell lines, which can potentially invalidate research findings.