The term "reproductive rights" is commonly understood to refer to legal developments in the area of abortion. When the term is employed the first thought that often comes to mind is "abortion rights." Abortion issues certainly fall within the general category of reproductive rights and, indeed, have attracted the most attention from the media, the legal community, and the public in general. However, there are a host of other important issues related to "reproductive rights." Contraception, sex education, condom availability programs, involuntary sterilization, surrogacy, and in-vitro fertilization are issues that have been taken up in the courts expanding the range of "reproductive rights" implicit in the Constitution.