Gamble & Ghevaert

Posts Tagged ‘international surrogacy law’

Today’s Guardian - Couples who pay surrogate mothers could lose right to raise the child

Tuesday, April 6th, 2010

By Denis Campbell, health correspondent.  Published in the Guardian, Monday 5 April 2010

Childless couples who acquire a baby using a surrogate mother abroad risk not being recognised as its parents in Britain if they flout British law by paying fees, fertility lawyers have warned.

Such payments, which can be as high as £30,000, could lead to those who have made them being refused permission by the high court to become the child’s legal parents, specialist solicitors say.  The Human Fertilisation and Embryology Act 1990 allows couples entering into deals with a surrogate mother overseas to pay her only what is allowed here – “expenses reasonably incurred”, such as compensation for time off work, medical bills and living expenses.  But lawyers handling such cases have told the Guardian a growing number of couples are embarking on international surrogacy in places such as India, the US and Ukraine, and that many of them are in effect flouting the law by paying whatever is needed to get a child. This could cause serious problems for them and the children as the high court may not grant a parental order.

More couples have sought legal advice about international surrogacy in the past two years, fertility lawyers say. Finding a surrogate in the UK is difficult, and many see surrogacy abroad as their last chance, said Miranda Baker, a lawyer in the field.  Lawyers predict that more people will pursue such deals after tomorrow, when the law changes to allow unmarried and same-sex couples to apply for parental orders.

Last November Mr Justice Hedley heard that a Mr and Mrs A had paid $23,000 (£15,000) to acquire twins from a surrogate mother in California. Mr A was the biological father. His sperm had been used to fertilise an egg from an anonymous donor and embryos were implanted into the surrogate. It was clear that “a significant element, although it is difficult to specify exactly what, of the $23,000 represents a payment contrary to the [law]“, he said.

Among matters of public policy the case raised was that “the court should be astute not to be involved in anything that looks like the simple payment for [in effect] buying children”. Despite that, Hedley granted Mr and Mrs A a parental order.

Hedley took the same view in 2008 in the case of X and Y – the first international surrogacy case the high court ruled on. A married couple whose repeated attempts to become parents had failed had twins known as X and Y using a Ukrainian surrogate. They also paid more than was “reasonable” to the woman, who used the money to put down a deposit on a flat, but obtained an order.

Sam King, a family law barrister specialising in assisted reproduction, warned couples having a baby through surrogacy abroad not to assume the high court would retrospectively endorse an arrangement that was “obviously commercial”. “They are taking a chance [by paying large sums]. Not all judges may be as generous as Mr Justice Hedley has been so far. All you need is one family to be denied a parental order because too much money has been paid for the whole thing to be thrown into confusion.”

Natalie Gamble, a lawyer who acted for the parents in both those cases, said: “If you don’t get a parental order the English couple aren’t seen as the child’s legal parents and you are committing an offence if you are caring for a child that’s not yours. You have to tell social services if you’re doing that.”

International surrogacy is hugely controversial. “It’s unethical and exploitative because the trade is all one-way,” said Breedagh Hughes, a Royal College of Midwives spokeswoman, on the ethics of childbirth. “It reduces babies to the level of commodities.”

Jonathan, a 32-year-old nurse, tells how he and his civil partner, Colin, 33, a financier, spent $150,000 (£98,000) on surrogacy to become the parents of Harriet, who was born in California last year. They live in London.

“We began discussing having a child in 2006, when we were deciding to become civil partners. I was feeling broody, and had always wanted to have my own biological child. We opted to pursue surrogacy in California because we would get legal custody there of the child before it was born and the surrogate would have no legal relationship to the baby.

“My sperm was introduced to eggs left by an egg donor: they were fertilised in an IVF clinic in Los Angeles and two of the embryos were implanted into the surrogate. She simply carried the child for nine months.

An agency in LA found both the egg donor and the surrogate. We never met the egg donor or knew who she was, but knew her medical history, results of her genetic tests, what she looked like and so on. We did meet and get on well with the surrogate, who was called Jennifer. She had two daughters of her own and had been a surrogate once before. There was no coercion. We had a contract, and Jennifer specified things in that like that she wanted back massages and a big hotel room for her family to stay in when she was giving birth.

Agencies in California quote a price of $100,000 to $150,000 to do everything relating to a child. The whole process wasn’t too difficult, and cost us about $150,000. We paid the embryologist $60,000, though that included the harvesting of the donor’s eggs, the IVF and the transfer of the embryos into the surrogate. It was $40,000 for the surrogate and $10,000 for the egg donor, plus $10,000 to the agency, who supplied the donor and the surrogate. Then there was $10,000 for our lawyer, $5,000 for the medical and psychological screening and another $5,000 for medication for both the donor and the surrogate, to ensure they were in cycle at the same time.

“Bringing Harriet into the UK nine months later was incredibly difficult, though, and we engaged lawyers to help us. She had to come in as an immigrant on a US passport on a six-month tourist visa. When we later filled in a form to get her British citizenship, we put ‘not known’ in the section headed ‘mother’. She now has dual nationality and is legally ours under Californian law. If we do apply, it could be an issue that we paid well over the ‘reasonable expenses’ limit – that is, we paid a fee. That’s illegal in this country, but allowed under Californian law.

“We shouldn’t have to seek a parental order. She was conceived and born in California as our child, and her birth certificate says who her parents are, so the courts here should respect Californian law.

Having to apply for a parental order, where there’d be an assessment of Harriet’s welfare and Colin would have to prove that he’s no danger to her, is an inequity. Anybody else can go out, get drunk, get pregnant, bring up a child appallingly and face no intervention or legal barriers.

I resent people saying that British couples who resort to surrogacy are buying babies abroad. We didn’t buy Harriet: she’s not picked off a shelf. She’s not a ‘designer baby’.

We had our own child and had a great team to help us. All we did was rent a woman to carry her. We paid for the services of an embryologist and an incubator who walks and makes good babies – but we didn’t buy a baby. She’s my daughter biologically, and she’s our baby.

A lot of heterosexual couples in the UK spend a lot of money having many cycles of IVF at £5,000 a time – is that not buying a baby?”

Only first names have been given to protect the family’s identity

More information on surrogacy law and international surrogacy law from the Gamble and Ghevaert website.

“International Surrogacy, Fertility Tourism and the American Bar Association” article by Louisa Ghevaert published in The Review

Tuesday, February 9th, 2010

Back in October 2009, Louisa Ghevaert was invited to speak to the American Bar Association’s Family Fall Conference in Montreal and give an English law perspective on international surrogacy arrangements.  Read her published account in The Review, the journal of the Association of Family Lawyers (Resolution) with a membership of 5,500.

US assisted reproduction attorneys were keen to get to grips with English surrogacy law as it applies to British people thinking about building their family through surrogacy in the US and the legal pitfalls they face navigating a safe legal path home to the UK after the birth of their surrogate born child.

US assisted reproduction lawyers expressed concerns that British parents may breach British immigration control by travelling home using their surrogate born child’s US passport.  They expressed further concern that US court orders recognising British intended parents as legal parents are not automatically recognised in England and Wales and that British intended parents could in certain circumstances commit a criminal offence in caring for their surrogate born child in the UK if they failed to apply for a parental order to be legally recognised as parents.

For more information about international surrogacy and the legal issues surrounding this visit our international surrogacy pages.

Louisa Ghevaert at the American Bar Association’s national family law conference in Montreal

Monday, October 26th, 2009

Louisa Ghevaert was delighted to be a conference speaker at the American Bar Association’s national family law conference in Montreal (9-11 October 2009). 

Speaking at a session attended by in excess of 50 specialist assisted reproduction lawyers from across the USA and Canada, Louisa spoke about the complex legal issues associated with cross-border surrogacy arrangements, as part of a panel which also included leading lawyers and academics from the USA, Canada and India.  Louisa’s talk reviewed the history and context of English surrogacy law, practical problems and issues for British couples considering foreign surrogacy, the key case of Re X and Y (Foreign Surrogacy) 2008 and the implications this has for UK-US surrogacy arrangements.

21st Century Surrogacy in the UK: bust or boom?

Friday, May 29th, 2009

There is no denying that the demand for surrogacy is rising.  It is no longer the taboo subject it once was, with India and certain US states widely reported as surrogacy “hotspots” and high profile celebrities, such as Sarah Jessica Parker, having embraced surrogacy.  Restrictive laws in the UK are driving increasing numbers of British people abroad for surrogacy and many are unwittingly falling foul of English law as a result with serious consequences. The middle ground, which England adopted decades ago to deal with small numbers of altruistic surrogacy arrangements, can no longer cope with the realities of widely available foreign commercial surrogacy.  English surrogacy law is now demonstrably inadequate.

The question is what should be done about it?  The problem is complex and it raises difficult ethical issues. 

One of the most basic objectives of English surrogacy law has been to restrict the payment of more than reasonable expenses to surrogate mothers, reflecting concerns about the exploitation of surrogate mothers, commodification of surrogate-born children and contravention of social beliefs that, just as body parts cannot be sold, neither should such intimate services. 

Existing surrogacy law was also made to reflect the sanctity of marriage and in the belief that no mother should be forced to hand over a baby to whom she has given birth. As a result English law states that the surrogate mother is always the legal mother of the surrogate born child (even if the commissioning mother’s or donor eggs have been used) and that the surrogate’s husband is always the legal father unless it can be shown he did not consent to the surrogacy arrangement (which is rare in practice). 

The net legal result is that British couples conceiving abroad using a married surrogate (and most surrogates tend to be married as they are deemed to be more stable and secure) have no legal connection with their surrogate-born child.  The legal parents are the surrogate mother and her husband.  The commissioning parents have no right to care for the child in the UK, may fall foul of immigration law and entry clearance provisions and cannot confer British citizenship.  To make matters worse, they are likely to have paid more than reasonable expenses if their payments to the surrogate mother contained any element of a “reward”. The reward element then requires close judicial scrutiny and authorisation as part of a complex parental order application to reassign legal parenthood from the surrogate parents to the commissioning parents and resolve the legal problems.

Solution

The long term solution must be changes in the law. This needs joined up thinking to take into account other legislation (most notably immigration and children law).  But inevitably, there will be no quick fix, leaving increasing numbers of people in a legal minefield.

Legislative change requires public debate and the government should consider commissioning an up to date in-depth report on surrogacy.  The government last commissioned such a report in 1997 (The Brazier Report) although no action was ever taken to implement its recommendations. Surrogacy needs to be revisited and examined from the perspective of life as it is now – with ready access to the internet and more accessible fertility treatment worldwide.  Difficult ethical and moral questions need examination and this is a challenging exercise requiring the best minds and a cross section of society.

In the meantime, there needs to be better access to good quality information about surrogacy and the legal implications.  At present, all too often people discover the legal difficulties after conception or birth and are then caught like rabbits in a headlight.  Fertility clinics, public bodies, not for profit institutions and lawyers need to do more to communicate the issues effectively to those contemplating or undergoing surrogacy.

The issue of commercial payments needs careful review.  Is it right or fair and reasonable to continue to prohibit commercial surrogacy? The current middle ground approach, which allows the authorisation of commercial payments by a judge after the event, is a costly, lengthy and cumbersome way of dealing with matters on a case by case basis.  Commercial surrogacy is a ticking time-bomb and one that looks set to explode.

The issue of legal parenthood needs re-examination.  Should a surrogate mother’s husband be treated as legal father (even where he has no biological connection)?  If not, this may be one way of short-circuiting some of the practical issues associated with foreign surrogacy, affording the commissioning parents some legal rights and responsibilities for their surrogate child automatically from birth. However, it would not protect and resolve the commissioning mother’s legal position, leaving her without any legal status for the child and arguably not in her or the surrogate-born child’s best interests longer term.

Assessment of different ways of resolving the legal issues surrounding surrogacy issues, to include the possibility of pre-birth orders may also be useful.  Commissioning parents crave greater certainty because surrogacy contracts are unenforceable under English law and because the surrogate parents currently have an absolute veto and can prevent the making of a parental order if they so chose.  The removal of the non extendable six month deadline for application for a parental order should also be considered.

Practically speaking, it is no longer an option to leave the issue of surrogacy in abeyance.  Surrogacy laws and practice need to be reviewed as a matter of urgency.  The foreign surrogacy industry is booming and the foundations upon which English surrogacy law were made look set to bust at any moment. 

More information from the Gamble and Ghevaert website about international surrogacy law.

 

 

 

Natalie Gamble joins growing media debate on Indian surrogacy

Friday, May 22nd, 2009

We are delighted that the London Evening Standard is raising awareness about this important issue.    See Natalie’s comments quoted in the Evening Standard yesterday.

Read more about international surrogacy law on our website.