Wednesday, 10 September 2014

The Concept of Property in Human Bodies

Do we have property in our bodies? Internationally? In the Kenyan legal context?
A question that pegs new age property scholars. Some people in the diaspora can sell their skin for advertisement space[1]in the sense that one agrees to get a tattoo of a company logo for a price. Through such a deal the human’s body becomes a commercial space and but also assumes an aspect of alienability, a 3rd party now enjoys a proprietal interest in the sellers body.[2] Is it now right to say that the seller owned that which he sold? How can we characterize the legal relationship that the seller now has with his body?
2nd example: Disembodied human skin is used by biotech companies to create an array of products, ranging from life-saving skin grafts to anti-aging creams[3]. Biotech companies purchase the tissue and convert it into useful and profitable products[4]. A chain of skin ownership stretches from the procurement agency to the biotech company to the patient who receives a skin graft. But what of the person whose body originally produced the skin tissue? Did the originator of the skin ever “own” it in the same sense that the biotech company owned it?
Advancements in biotechnology have complicated this question of human body ownership by producing an extraordinary array of uses for the human body[5]. However the notion of referring to the human body as property because it is argues that the human body is special[6] and referring to it as property debases it[7]. It also not clear how a human body can be owned by even the human himself because it is perceived that the human is one with the body such that one cannot both be oneself and own oneself.[8] Render Argues that all the objections to the human body as property debate is based on misunderstandings of property, of owning oneself and of the consequences of adopting a property framework vis a vis the human body.
 Property has been argued to be a bundle of sticks relationship with other people in regard to things or a collection of Hofheldian correlative (rights, privileges, powers, and immunities) that regulate the relations of people with respect to valued resources.[9] “Core” property rights are in fact in rem rights, and that in rem rights are qualitatively distinct from in personam rights, Merrill and Smith by coming up with this explanation brings our attention to the tangibility, the “thingness” of property rights, thereby articulating a qualitative line between property rights and other species of entitlements[10], tangible property rights hold a distinct form of entitlement from the rest. The “thingness” of property rights is significant in that we know things about our legal duties with respect to a thing that is owned even if we do not know who the owner is. We know, for example, that we cannot take it, or use it, or destroy it without permission. We know, too, that we have these duties with respect to a thing even though we are not party to a contract[11], Smith argued that because property rights create duties that attach to “everyone else,” they provide a basis of security. This feature of property imposes an informational burden on large numbers of people. As a consequence, property is required to come in standardized packages that the layperson can understand at low cost. This is provided for by the principle of numerus clausus( number is closed), it limits the kinds of interests that are possible in property to a set number and thereby prevents the customization of property interests.[12] It is appropriate when we are concerned about ownership interests that append to “things” because of the inherent “thingness”—the in rem character—of the tangible subjects of property. When I convey an interest in my real or personal property, the scope of the interest I can convey is inherently limited by the entity itself (e.g., I cannot convey to you more house than I have). So property interests in the tangible objects of property are more than “little empty boxes filled with a miscellany of use rights” indistinguishable from other types of entitlements.[13]
The law is silent on the question of the legal status of a living human body. A person, of course, enjoys a legal identity. A person’s blood, organs, tissue, sperm, and ovum can enjoy legal identities.[14]A deceased body enjoys a legal identity. But a living body is omitted from this taxonomy. For something to fall within the concept of property the criterion is two; the entity must be valued (i.e., the entity is capable of being put to a valuable use); and it must be “ownable” (i.e., ownership rights backed by force of law) but the entity of the living human body is impervious to the criteria.
In Moore v. Regents of the University of California[15], the court was called upon to determine whether John Moore, who suffered from hairy-cell leukemia, “owned” or had other property interests in his spleen after it had been removed from his body during the course of a medical treatment. In the course of his treatment, Moore’s doctors discovered that Moore’s white blood cells were clinically unique. Without Moore’s knowledge or consent, his doctors retained his spleen for medical research .The research culminated in the patenting of a highly lucrative cell line, and Moore, upon discovering that his cell structure formed the basis of the cell line, sued the doctors for conversion on the theory that he retained a property interest in his spleen after its removal. The court found that he lacked the requisite ownership interest, the extension of conversion law into this area will hinder research by restricting access to the necessary raw materials, Exchange of scientific material will be compromised and lastly the extension of the concept of property to bodily materials will create uncertainty of title as it would be prohibitively expensive to investigate the origin of bodily materials which enhances biological research, a public good. The court however said in passing that if Moore was informed of it then he would have secured his property interest. In saying this the court set the bar for proprietary interest as informed consent although they referred to this not as proprietary but as bodily integrity interest on the basis of informed consent then the court adopted an in rem quality of the interest in the Spleen. So rather than denying the possibility that we own our bodies, the holding in Moore actually relies upon the assumption that we own our bodies. If Moore had no interest in his spleen prior to the splenectomy, the decision would be rendered incoherent.
Property rights are in rem interests, and that in rem interests are unique in that they accommodate the attributes of “thingness” attendant to the tangible world.[16] The primary means by which in rem interests accommodate these attributes of “thingness” is through the principle of numerous clausus, which limits the forms that interests in objects can assume. The living human body (and its constituent parts and products) fits squarely within this in rem rights paradigm. As a resource, the human body is finite and unique not only in that there are an exhaustible number of living human bodies, but also in that living human bodies are not fungible. My body is not an adequate substitute or replacement for another’s body. Each living body serves a unique and nontransferable function, and a person who is separated from her body cannot be made whole with either money damages or a replacement body. Of all the other core property interests, only real property shares this attribute of uniqueness so completely, and real property is the model upon which our in rem understanding of rights is built[17].
It should be noted that the Court in Moore carefully avoided describing human tissue as “property,” but in doing so the court utilized the tools already in place within our legal scheme for dealing with tangible, finite resources to protect against the typical pitfalls that hinder the productive use of tangible resources. The legal status of the living human body has been suspended in a kind of limbo as courts following Moore persist in assuming without acknowledging that we have a limited, standardized set of rights in our bodies, yet decline to identify those interests as “property” thus we are left with an incoherent doctrine that deems our bodily material to be “property” only once it is separated from us. The unwillingness to describe the body as property is predicated on conceptual misunderstandings.
Much attention on human body as property is centered on sensationalized stories such as black markets for organs that are forcefully transplanted from unknowing donors. However our social practices and our linguistic description of those practices suggest that our conventional concept of “ownership” extends to the human body[18].
What is the content of the property interest we hold in our bodies? To have an in rem property right is to have the exclusive right to use a tangible entity including, minimally, the right to exclude others. The content of our control is limited by public policy, in the context of a living human body; the exclusive right to use is inherent in the structure of the entity itself. A living human body is the most immovable of all resources, the person who is born into a body as that body’s “original owner,” we can readily say that no one else can use a human body in a manner that is in any way commensurate to the manner that the original owner uses it. This is not to say that an original owner cannot be separated from her body[19]but such a separation necessarily results in death, and death necessarily transforms the living human body into another kind of entity, a body is only “ownable” once and can only be owned by the original owner. Our relationship to our whole and living body assumes the form of an inalienable property right. “Inalienable” here means that it cannot be separated from the owner of the right and transferred to another. The content of one’s inalienable property right in her body is, minimally, the exclusive right to use her body (e.g., to live), a right that also necessarily encompasses the right to exclude all others (e.g., to exercise sexual and medical autonomy, to be free from injury to the body). These rights are necessarily essential to the concept of “ownership” in the context of the human body. Further, our existing legal structure (although silent on the legal status of the living human body) backs an exclusive right to use the body with the force of law. For example, rape law.
Solving the conceptual misunderstandings: Much of the problem lies in describing the human body as a thing or object and the notion of owning other people as it reminds us of horrors such as slavery. Most of these sets of worries about identifying a living human body as property is rooted in a conflation of the concepts of “body” and “person.” These two concepts, while certainly related, are sometimes treated as coterminous, and if they are coterminous (i.e., if a person is no more or less than (or nothing other than) her body and vice versa), it may be incoherent to say that a person owns her body.
What is a person? Is an entity to whom rights and duties attach and laws apply[20].In the context of the human body ownership an “original owner” of a body is the person who is born with that body.[21]So it is it is coherent to say that a person “owns” her body based on the fact that an owner in this context is a legal concept, and when we speak of a person who “owns”, we are referring to the legal concept of “person” (i.e., the entity upon which rights are conferred in a particular legal context) and not the conventional concept of “person,” which is illustrated by the fact that owners of property can be non-natural persons.
Persons and Bodies: Is a person and the body the same thing? This is known as the mind body problem, which considers whether one of two mutually exclusive accounts of the connection between a person and her body is correct[22].
1st is Dualism: it holds that a person is constituted of both physical properties (one’s body) and non-physical properties (usually, one’s mind, but sometimes one’s soul, intellect, consciousness, or identity). However this fails as it is incoherent for one to be both the subject and object of ownership[23].
2nd is Reductionism: it holds that all phenomena related to the person/body connection depend upon (or can be reduced to) physical phenomena.[24]According to the radical reductionist view not only are all mental phenomena reducible to physical phenomena, but a person (or self) is composed of physical and psychological continuity and nothing more. However, if we embrace the radical reductionist view then it is not clear that a coherent normative distinction between “mere objects” and “persons” exists. If it is indeed the case that we are nothing apart from the sum of the physical processes of our bodies, then the “thingness” connotation is sensible. It may be the case that our physical processes give rise to special attributes (e.g., sentience and sapience) and that these attributes are particularly worthy of dignity and moral respect, but it is not clear how describing an entity that has these attributes as “property” debases that entity, when the attributes themselves are reducible to a set of things. Seeking inspiration from these two theories it is concluded that a ‘person’ and ‘body’ are distinct concepts. Hence it is coherent to say that a person owns his/her body.
Am I supporting slavery? The thought of regarding bodies as property evokes anger even within I because the reduction of person to things indirectly hints at slavery. What does it mean to own oneself? When used in a property law context, as here, the phrase usually takes on quite a literal meaning: the question asks do we own the corporeal entity—the physical artifact—that is our living human body[25]? Property law is concerned with the right to exert dominion over and retain an interest in the biological capacities and physical artifact of our corporeal bodies[26]. So the term “self-ownership,”  means the right of exclusive use of one’s body where that right is backed by the force of law, it is only vested in the person born into that body, it is inalienable therefore in the advent of slavery such ownership was not possible of  a slave by the slave driver. This is the distinction between owning a person and a body. The human body law should pay specific attention to the right of exclusion of others as this is arguably the most powerful incident of ownership in the body.
Am I calling for a commodification of the human body and the Domino effect of this? Commodification when used in this context, means to transform an entity that has use value (people can make valuable use of the entity) into an entity that has both use and exchange value.[27]
Scholars such as Margaret Radin, Martha Ertman, Joan Williams are concerned that;
·         By creating unfettered legal markets in these “contested commodities” we would aggravate or perhaps worse, justify existing exploitations of people[28]
·         Commercial markets would exacerbate (or, again, perhaps justify) radical inequities in the distribution of life-saving body parts along racial, ethnic, geographic, and socioeconomic lines.[29]
·         Making the human body available to legally sanctioned commercial markets lowers the dignity status of the human body and, consequently, devalues the concept of personhood
Alienation in this context means to place in a commercial market, and in declining to identify a property interest in the human body the Moore court is perceived by some scholars to have succeeded in protecting the human body from at least this kind of commodification. These concerns are misplaced;
·         Describing a thing as property does not increase that entities capacity to be traded in the market ipso facto in the context of the ownership right in a living human body, the explicit designation of property actually makes commodification of the body less possible because it reveals that the right of exclusive use is inalienable.
·         A distinction must be drawn between alienation of the human body and alienation of the capacities of the human body
It has been stated that the body as property has some aspect of inalienability, this is to not say that it cannot be a commodity because body uses such as prostitution, surrogacy, pornography or advertising are freely done, however this are just aspects of/capacity of the human body that becomes a tradable entity. But, the core of body ownership the right to use and exclude cannot become a commodity.
The fact that body ownership is inalienable means that regarding it as property does not make it vulnerable to commodification but rather serves as an impediment to commodification[30] because all this body uses will not be done freely in a lacuna, they will be governed by the law which will enhance fair and lawful practices.
Still many are concerned that denoting the human body as a property right connotes market alienability; this is misplaced because the right to transfer, where it exists, is an incident of property, not necessarily criterion of property[31]. It is perceived that designation of “property” is bound to affect the alienability of the capacities of the human body; developments in biotechnology have made it possible to transfer not only body parts but also capacities of the human body. This development have created somewhat of a second order value to our bodies, the first-order value of a human body is the unique value it provides to the person who is born with it. For example, my body uniquely sustains my particular life.[32] No one else shares the same relationship of particularity and necessity that I do with my own body and its constituent parts[33].
Bio technology has created a second order value to body’s as now one’s body is valuable to another for example a woman’s womb, ovum, man’s sperm. Although the capacities of the human body have become increasingly alienable, it does not follow that those capacities necessarily must (or can, or should) become commodities.
The Reproductive Healthcare Bill: this a bill that is in parliament that addresses the reproductive functions of the human body and provide a  right to make decisions regarding reproduction free from impediments. “Reproductive  health"  means  a state  of complete physical,  mental and  social well-being,  and  not  merely the absence of  disease  or infirmity,  in  all  matters  relating  to the reproductive  system  and  to its  functions  and  processes. It provides for contraceptives, rights gestational surrogacy, Rights to abortion. The bill is currently in the senate so the people impatiently wait to grasp this new property right legally.


[1] See Albert Chen, Tattoo You, SPORTS ILLUSTRATED, Mar. 18, 2002, at 26. (referred to as human bill boarding)
[2] See, LEASE YOUR BODY, www.leaseyourbody.com (last visited July. 5, 2014).
[3] See Kerry Howley, Big Business in Body Parts, L.A. TIMES, Mar. 6, 2007, at A17; Coco Ballantyne, A Cut Above the Rest?: Wrinkle Treatment Uses Babies’ Foreskins, SCI. AM. (Feb. 12, 2009)
[4] See David Solomon, Informed Consent for Routine Infant Circumcision: A Proposal, 52 N.Y.L. SCH.L. REV. 215, 220 (2007–2008)
[5] Rohan Hardcastle, law and the human body: property rights, ownership and control 3–7 (2007)
[6] See Richard Gold, Owning Our Bodies: An Examination of Property Law and Biotechnology, 32 SAN DIEGO L. REV. 1167, 1192–93 (1995).
[7]Michael J. Sandel, What Money Can’t Buy: The Moral Limits of Markets,  in RETHINKING COMMODIFICATION: CASES AND READINGS IN LAW AND CULTURE 122, 124 (Martha M. Ertman & Joan C. Williams eds., 2005)
[8] David Price, From Cosmos and Damian to Van Velzen: The Human Tissue Saga Continues, 11 MED. L. REV. 1, 28 (2003)
[9] Honoré in his landmark paper Ownership
[10] Thomas W. Merrill & Henry E. Smith, Essay, What Happened to Property in Law and Economics?, 111 YALE L.J. 357, 385 (2001)
[11] Ibid
[12] Sup n14
[13] As had been described by Merrill and Smith Ibid
[14] See Radhika Rao, Property, Privacy, and the Human Body, 80 B.U. L. REV. 359, 363–64 (2000)
[15] (51 Cal. 3d 120; 271 Cal. Rptr. 146; 793 P.2d 479)
[16] See Avihay Dorfman & Assaf Jacob, Copyright as Tort, 12 THEORETICAL INQUIRIES L. 59, 74 (2011), at 73
[17] See Carol M. Rose, Property as the Keystone Right?, 71 NOTRE DAME L. REV. 329, 351 (1996)))
[18] J. W. Harris, Who Owns My Body, 16 OXFORD J. LEGAL STUD. 55, 77–84 (1996).
[19] Meredith M Baker ‘Law of the Body’ pg 5 A. L. S Review
[20] See Elizabeth A. Martin (2003). Oxford Dictionary of Law (7th edn). Oxford: Oxford University Press.
[21] See Jesse Wall, The Legal Status of Body Parts: A Framework, 31 OXFORD J. LEGAL STUD. 783, 785–86 (2011)
[22] See William D. Hart, Dualism, A COMPANION TO THE PHILOSOPHY OF MIND265, 265 (Samuel Guttenplan ed., 1994).
[23] See also GILBERT  RYLE,  THE CONCEPT OF MIND 15–18  (Univ. of Chi. Press 2002) (1949)
[24] See Howard Robinson, Davidson and Non reductive Materialism: A Tale of Two Cultures, in PHYSICALISM AND ITS DISCONTENTS129, 129–30 (Carl Gillett & Barry Loewer eds., 2001).
[25] See Guido Calabresi, Do We Own Our Bodies?, 1 HEALTH MATRIX5 (1991).
[26] Sup note 19. Page 16
[27] See Martha M. Ertman & Joan C. Williams, Freedom, Equality, and the Many Futures of Commodification, Preface to RETHINKING COMMODIFICATION, Williams eds., 2005pg 22
[28] See DEBRA SATZ, WHY SOME THINGS SHOULD NOT BE FOR SALE199 (2010)
[29] See K. A. Bramstedt & Jun Xu, Checklist: Passport, Plane Ticket, Organ Transplant, 7 AM. J. TRANSPLANTATION 1698, 1698 (2007)
[30]  See Peter Halewood, On Commodification and Self-Ownership, 20 YALE J .L. & HUMAN. 131, 141 (2008)at 131
[31] See Jesse Wall, The Legal Status of Body Parts: A Framework, 31 OXFORD J. LEGAL STUD. 783, 785–86 (2011),
[32] See Margaret Jane Radin, Property and Personhood, 34 STAN. L. REV. 957, 966 (1982)
[33] Ibid

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