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"Jehovah's Witnesses,Blood Transfusions, and the Tort of Misrepresentation"
The State's right to intrude in a religion's affairs
A state can intrude, however, either directly or through allowing tort action, in the right to exercise religious beliefs provided the state's action can meet a four-part test:
1. Government must have an important or compelling state interest.
2. The "burden of expression must be essential to further" this interest.
3. The "burden must be the minimum required to achieve" this interest.
4. The measure must apply to everyone, not just the questioned religion. 
Government intervention into religious exercise through meeting this test is rooted in legal precedent. In Reynolds v. U.S., one of the first decisions limiting religious freedom, the Supreme Court upheld a law criminalizing polygamy because of the state's compelling interest in protection of the family unit.  Additionally, courts are now willing to allow aggrieved citizens to sue their church if it misrepresented a secular fact.  For example, one court has held a religious organization liable for misrepresenting its use of donated funds. 
Similarly, the Catholic Church became engulfed in a flood of tort law suits following revelations that some of its priests sexually abused minors and that the church allowed known sex-offender priests to continue in their posts. 
One of the primary cases dealing with a religious organization's misrepresentations is Molko v. Holy Spirit Association for the Unification of World Christianity ("Unification").  The California Supreme Court held that ex-followers could sue the church for fraud in its deceptive recruitment practices. ..... The California Supreme Court, however, held that the church's deceitful recruitment practices were unprotected, religiously-motivated conduct and therefore subject to court scrutiny.  The court stated that holding a religious organization liable for misrepresentations is the best solution, as it does not implicate either the church or its members' right to associate or worship, or force them to perform acts contrary to their religious belief.  The court concluded that allowing tort relief for misrepresentations only closes "one questionable avenue" for recruiting members.  The court reasoned that opening religious organizations to traditional tort liability protects persons from being harmed and is nondiscriminatory since it applies equally to religious and non-religious groups. 
The Watchtower Society misrepresents premature infants' capacity to survive low blood levels
The pamphlet next quotes a study on premature infants by Dr. James Stockman III:
With few exceptions, infants born prematurely will experience a decline in hemoglobin in the first one to three months . . . The indications for transfusion in the nursery setting are not well defined. Indeed, many infants seem to tolerate remarkably low levels of hemoglobin concentration with no apparent clinical difficulties. 
It appears by this that the Society is subtly informing Jehovah's Witness parents with premature infants that low blood count is common, thereby suggesting that doctors unnecessarily push blood transfusions.
Jehovah's Witness parents may be led to believe that their infants do not need a transfusion, as Dr. Stockman said that many infants can survive low hemoglobin levels. However, Dr. Stockman outlined two situations in which transfusion would be necessary: (1) "certainly before ten percent of blood volume" had been withdrawn for blood sampling; and (2) when stabilized premature infants continue to render hemoglobin levels less than 10, show low available oxygen, and have another sign such as "poor feeding, dyspnea, tachycardia, tachypnea, diminished activity, and pallor."  Dr. Stockman recognizes that once a preterm infant has stabilized, transfusions are not needed if hemoglobin is "greater than 10 to 11 g/dl."  The Society could have more accurately summarized Dr. Stockman's recommendation by claiming that most preterm infants do not need transfusions once they have stabilized, but those who need frequent blood sampling or continue to have hemoglobin counts less than 10, along with other problems, may need a transfusion. The pamphlet highlights other medical doctors' discussions of hemoglobin counts and the decision to transfuse, but fails to mention enough detail about Dr. Stockman's study to inform the reader of his recommendation about premature infants coping with either loss of blood volume or consistently low hemoglobin levels.
Furthermore, the Society's quote that the decision to transfuse is "not well defined" may serve to incite fear that the medical community is unnecessarily pushing blood transfusions. The pamphlet's preceding two paragraphs described the doctor's decision based on hemoglobin level of "10" as "cloaked in tradition" and "shrouded in obscurity," and included the fact that patients with hemoglobin levels of "7" showed no work deficit.  A reader could easily conclude from this that "not well defined" meant that doctors were also guessing at whether to transfuse a newborn. In reality, Dr. Stockman was contrasting the doctor's "not well defined" decision about newborns relative to the situation in older adults and children. . . ."  In so doing, Dr. Stockman emphasized the doctor's complex analysis of the many tests that show the physiological nadir most infants undergo during their three-month, post partum transition from the fetal environment.  Dr. Stockman noted that the complexity of the doctor's decision needed to include variables such as hemoglobin and erythropoietin levels, reticulocyte count, oxygen affinity/release levels, and PO2 readings.  Dr. Stockman's article was not a conclusion that pediatricians' recommendations for premature infants were ill-informed, but rather that they inherently involved more variables and were less clear-cut than a decision involving a transfusion for a healthy infant, older child, or adult.
Parents' right to choose no blood for children is misrepresented
Courts are frequently called upon to order transfusions for children of Jehovah's Witness parents. In its legal information section entitled "You Have The Right to Choose, " the pamphlet informs parents that courts recognize parents' rights to make medical decisions for their children:
In 1979 the U.S. Supreme Court stated clearly: "The law's concept of the family rests on a presumption that parents possess what a child lacks in maturity, experience, and capacity for judgment required for making life's difficult decisions . . . Simply because the decision of a parent [on a medical matter] involves risks does not automatically transfer the power to make that decision from the parents to some agency or officer of the states."Parham v. J.R. 
The same year the New York Court of Appeals rules: The most significant factor in determining whether a child is being deprived of adequate medical care . . . is whether the parents have provided an acceptable course of medical treatment for their child in light of all the surrounding circumstances. This inquiry cannot be posed in terms of whether the parent has made a 'right' or a 'wrong' decision, for the present state of the practice of medicine, despite its vast advances, very seldom permits such definitive conclusions. Nor can a court assume the role of a surrogate parent.In re Hofbauer 
While these quotes are not in themselves inaccurate, the Society does not inform its readers that these particular cases do not involve minors of Jehovah's Witnesses who need immediate, life-saving blood transfusions. Rather, Parham v. J.R. deals with the parents' wish to obtain psychiatric help by civilly committing an uncontrollable minor contrary to the minor's objections.  Moreover, the relevant facts in Parham did not involve the parents' refusal to accept medical treatment on religious grounds. Indeed, concurring Justice Stewart wrote that a state would have constitutional grounds to preempt the parent's decision, and defended this position by referring to a seminal case against a Jehovah's Witness parent who mandated that her minor niece engage in selling Society magazines in violation of the state's child labor laws.  In re Hofbauer deals with the parents' choice of using nutrition instead of chemotherapy to treat Hodgkin's disease.  The Hofbauer court also differentiated its facts from cases involving parents' religious refusal of medical treatment, including a reference to a specific Jehovah's Witness blood case, a fact which the pamphlet omitted.  From these examples, a clear precedent can be seen that many courts will order blood transfusions for minors over and against the parents' wishes.  Thus, Jehovah's Witness parents may be surprised to learn that precedent denies their supposed "right" to make martyrs of their children. 
The need for blood transfusion in complex surgery is misrepresented
Most surgeries do not require blood transfusions. Some surgeries, such as coronary bypass, hip or knee replacement, hepatic resections [liver surgery], and radical prostatectomy [prostrate removal], are a higher risk.  The pamphlet states that bloodless surgeries are safe and quotes as support a study by Dixon B. Kaufman concerning renal (kidney) transplants: "The overall results suggest that renal transplantation can be safely and efficaciously applied to most Jehovah's Witness patients."  More telling, however, is the self-incriminating information that the Society omitted (emphasis on Society's actual quote):
Jehovah Witnesses had an increased susceptibility to rejection episodes. The cumulative percentage of incidence of primary rejection episodes was 77 percent at three months in Jehovah's Witnesses versus 44 percent at 21 months in the matched control group. The consequence of early allograft dysfunction from rejection was particularly detrimental to Jehovah's Witness who developed severe anemia (hemoglobin (Hgb)* 4.5 per cent) two early deaths occurred in the subgroup with this combination. The overall results suggest that renal transplantation can be safely and efficaciously applied to most Jehovah Witness patients but those with anemia who undergo early rejection episodes are a high-risk group relative to other transplant patients. 
Since the pamphlet dedicates pages to anemia, why did the Society omit that the almost double rates for organ rejection as well as the study's clarification that "those with anemia" are a high risk group?
Summary of misrepresentations
At this point, a salient question emerges: Should the tort of misrepresentation be allowed to the victims of blood policy and their families who have come to the conclusion that the Society misrepresented the historical and medical science in its indoctrination literature? A court could conclude that each misrepresented statement is relatively insignificant. However, when taken together, the misrepresentations serve to warp the follower's mind regarding the actual medical and historical perspective. The Society deceives its followers into thinking that blood transfusions render one's immune system incapable of fighting cancers, when the actual link depends on the type of cancer. It builds a case that other doctors wish all surgeons would become bloodless surgeons, when in fact those doctors recognize the benefits of blood transfusions for those who are in desperate need. The Society "scares" followers into believing that accepting blood transfusions is equivalent to contracting contagious diseases, when the actual risks are one in several hundred thousand to a few million. The Society "placates" by suggesting adults and infants can tolerate low hemoglobin levels, despite medical knowledge that a healthy person has at least a one in three chance of not surviving a blood count lower than 7, with survival rates for people in high-risk groups being much lower. The Society falsely assures parents that they can legally refuse a blood transfusion for their child by citing cases that in no way substantiate such a position. The Society never reveals to its readers the actual risks of death when blood levels drop either slowly from anemia or quickly from hemorrhage. Instead, the Society gives its readers the impression that ultra low hemoglobin counts, such as 1.8, are easily survivable under the supervision of the right doctor. Only by looking at the overall effect of the Society's literature can one determine whether there are misrepresentations that induce a follower to accept the Society's life-threatening arguments without question.
The Watchtower Society fails to tell its followers of critical policy changes
Scientists can now isolate the red blood cell's most important fraction, hemoglobin. In lay terms, hemoglobin is what makes blood, blood; hemoglobin is responsible for transporting oxygen, transfused from bags, which can be used for treating anemic or bleeding patients. Hemoglobin for human transfusion has been studied and used for about 40 to 50 years, albeit with many complications making it medically impractical.  In 1985, the U.S. Army Blood Research Division began research to develop a more viable hemoglobin-based product to use in the battlefields as its shelf life is about one to two years and required no refrigeration. 
In 1992, the Society specifically banned hemoglobin, an isolatable component of red blood cells, and placed it alongside banned whole plasma, red blood cells, and white blood cells.  In 2000, The Watchtower declared that Witnesses could accept any fractions derived from whole blood cells, noting that medical science was advancing in its ability to break down primary components into secondary ones.  The 2000 Watchtower article, however, failed to specifically mention whether hemoglobin was now allowed, thereby leaving ambiguous the question of whether Witnesses could now accept hemoglobin without reproach from Jehovah. On 24 September 2000, the Sacramento Bee reported that a member of the Jehovah's Witness Hospital Liaison Committee approved the use of hemoglobin for Witnesses.  The 15 June 2004 Watchtower article, citing a policy dating back to 1981, also reiterated that Witnesses could individually accept fractions from whole blood cells, but failed to specifically list hemoglobin.  To date, The Watchtower still has not specifically publicized that it condones Jehovah's Witnesses accepting hemoglobin, leaving doubt as to the status of a previous directive singling it out as unacceptable.
Watchtower's current blood policy misrepresents the scope of allowed fractions
Surprisingly, the Society today allows its followers to accept ALL blood fractions (aka "fractions" or "components") without church sanction, provided a follower's decision is well considered. 
Currently, the Society depicts the allowed fractions as "minute" and omits pointing out the fact that the allowed fractions would, if added together, total the entire volume of blood they came from.  In 1990, a time when fractions were allowed, the Society declared that Witnesses abstain from blood in any form.  Because the Society depicts the fractions as minute and prescribes that Witnesses abstain from blood in any form, one might anticipate that today's Witnesses would be confused if they were aware of an actual equivalence between whole blood and allowed blood fractions.
If one adds the fractions together, they total a unit of whole blood, graphed as follows:
Percentage of total weight of blood. 
The Society's early literature described the connection using rather discrete numbers:
Awake! 01/08/1954 page 24: We are told that it takes one and a third pints of whole blood to get enough of the blood protein or "fraction" known as gamma globulin for one injection Those interested in the Scriptural aspect will note that its being made of whole blood places it in the same category as blood transfusions as far as Jehovah's prohibition of taking blood into the system is concerned.
The Watchtower 6/15/1985 page 30: Each batch of Factor VIII is made from plasma that is pooled from as many as 2,500 blood donors. It seems that by importing this blood product the AIDS virus was transferred to the British supply.
Today, the 15 June 2004 Watchtower admits that fractions are derived from blood, but no longer reveals the thousands of units of blood which are needed to make fractions:
By using component transfusions, physicians could spread donated blood to more patients, perhaps plasma to one injured man and red cells to another. Continued research showed that a component, such as blood plasma, could be processed to extract numerous fractions, which could be given to still more patients. 
The Society's choice to not inform its readers about the large quantity of blood units needed to produce the accepted fractions or that the fractions, if added together, would total whole blood, may be an attempt to defend itself against critics who question the sincerity of the Society's belief that it abstains from blood or only partakes in minute amounts.  The Red Cross urges people to donate blood to meet the Jehovah's Witness demand , and one particular Watchtower critic describes the Society's policy as similar to that of allowing a Jehovah's Witness to purchase an entire truck, but only part by part. 
This author supposes that the implicit language is the Society's signal to today's Witnesses that they may accept blood fractions while not alienating older Witnesses. One might anticipate that if the Society retracted its notorious blood ban, Witnesses would be alienated upon realizing that their very existence was falsely dictated. Moreover, non-Witnesses would likely scoff at the religion whose teachers were complicit in many needless, premature deaths. By making fractions appear minute, the Society may be appeasing followers with long-term illnesses who need blood fractions without directly admitting its traditional dogma has been retracted. It might also signal the Society's attempt to meet medical science in the middle as both advance towards using fractions. In any event, it is a misrepresentation for The Watchtower to label the current blood fraction policy "minute" in relation to whole blood, a deception that may lead followers to misunderstand the extent and scope of the allowed fractions. If followers actually understood the correlation, they might seriously question both the Society's purported belief that it abstains from blood and their own choice to forego needed blood transfusions.
Watchtower's current blood policy contains contradictions about autologous blood transfusions
The Society has never allowed its followers to pre-store their own blood in anticipation of planned surgeries (pre-operative autologous blood) because it believes blood, once outside the body, becomes impure.  The Society bases this belief on Leviticus 17:13, 14 and Deuteronomy 12:24 and holds that once blood has left the body, it should no longer be used, but should be spilled onto the ground and covered in dust.  In 1972, the Society applied this belief to hemodilution (a newly emerged technology whereby an external machine recirculates the patient's own blood outside his body) and banned the procedure.  But beginning in 1983, the Society reversed itself and approved hemodilution therapy, as it now considered the machines an extension of one's circulatory system. 
Of note is the 15 October 2000 Watchtower which expanded the permitted external blood medical procedures by directing followers to personally decide on techniques "in which a quantity of blood is withdrawn in order to tag it or to mix it with medicine, whereupon it is put back into the patient. . . . A Christian must decide for himself how his own blood will be handled in the course of a surgical procedure, medical test, or current therapy."  Unfortunately, the Society did not define "quantity" or "current therapy." The same article, however, reiterates the long standing ban on pre-operative autologous blood storing, transfusing one's own blood collected weeks before surgery, and declares that Jehovah's Witnesses "abstain from blood."  The patient is left in a quandary. Jehovah God allows a lab to withdraw an unknown quantity of blood, walk it down the hall to be mixed with other substances or to run tests on it, and later transfuse this blood back into the patient, provided it is "current." But, "current" apparently can not be "weeks," as in the case of pre-operative blood saving.
Courts look at the sincerity of the religion's belief.  The Society purportedly believes that blood once it has left the body is not to be used again. Contrast this belief against the Society's allowance of blood fractions, hemodilution machines, and "current" therapy transfusions of blood. It is a misrepresentation for the Society to state that it and its followers "abstain from blood."
Send a protest email NOW to Watchtower Society: tell them what you think of their blood policy.
 Wollersheim v. Church of Scientology, 212 Cal. App. 3d 872, 884 (2d Dist. Div 7 1989).
 Reynolds v. United States, 145 (1878).
 Stephen Senn, "The Prosecution of Religious Fraud," Florida State University Law Review 17 (Winter 1990): 328.
 Ibid., 342, referring to In re Heritage Village Church and Missionary Fellowship, Inc., 92 Bankr. 1000, 1006-07 (Bankr. D.S.C. 1988) (PTL used "separate, confidential bank account" to pay top executive officers without disclosing huge amounts paid to employees or church contributors and made "calculated attempts to conceal ministry finances.").
 Ira C. Lupu and Robert W. Tuttle, "Church Autonomy Conference, February 6-7, 2004, J. Rueben Clark Law School, Brigham Young University: Church Autonomy and Religious Group Liability: Article: Sexual Misconduct and Ecclesiastical Immunity," Brigham Young Law Review (2004): 1789.
 Molko v. Holy Spirit Association for the Unification of World Christianity, 46 Cal. 3d 1092 (Cal. 1988).
 Ibid. at 1117-118.
 Ibid. at 1117.
 Ibid. at 1119.
 How Can Blood Save Your Life?, 14, quoting study by Dr. James A. Stockman III in February 1986 Pediatric Clinics of North America.
 James A. Stockman III, MD., "Anemia of Prematurity Current Concepts in the Issue of When to Transfuse," Pediatric Clinics of North America 33, no. 1 (February 1986): 111, 125-26; but, article notes that "Apnea has not unequivocally been shown to improve following transfusion."
 How Can Blood Save Your Life?, 12.
 Stockman III, MD., "Anemia of Prematurity Current Concepts in the Issue of When to Transfuse," 111.
 Ibid., 125-26.
 Jehovah's Witnesses of Washington v. King County Hospital, 278 F. Supp. 488 (W.D. Wash. 1967) affirmed 390 U.S. 598 (1968) (Class action suit holding that State could order blood transfusions to minor children over the objections of the minors' parents); In the Matter of Baby Girl Newton, 1990 De. Ch. Lexis 48 (Del. Ch. Apr. 24, 1990) (Case not released for publication) (Court held that it was within the State's domain to order a blood transfusion for premature, anemic 2 day old infant.); Muhlenberg Hospital v. Patterson, 128 N.J. Super 498 (N.J. Super. Ct. 1974) (Court permitted blood transfusion to ill six-day-old infant because blood transfusion would likely prevent severe health damage.).
 How Can Blood Save Your Life?, 21-22.
 Parham v. J.R., 442 U.S. 584 (1979).
 Parham v. J.R., 442 U.S. 584 (1979) at 624, referring to Prince v. Massachusetts, 321 U.S. 158 (1943).
 In re Hofbauer, 47 N.Y. 2d 648 at 655 (NY Ct. of Appeal 1979).
 Ibid.; referring to In re Sampson, 37 A.D. 2d 558 (Supreme Court of New York, Appellate Division, Third Department June 28, 1971) (Court found Jehovah's Witness parent neglected son when she refused to permit him a blood transfusion.).
 Jehovah's Witnesses of Washington v. King County Hospital, 278 F. Supp. 488 (W.D. Wash. 1967) affirmed 390 U.S. 598 (1968); Novak v. Cobb County Kennestone Hosp. Auth., 74 F.3d 1173, (11th Cir. 1996); In the Matter of Baby Girl Newton, 1990 De. Ch. Lexis 48 (Del. Ch. Apr. 24, 1990) (Case not released for publication); In re McCauley , 409 Mass. 134 (1991); Muhlenberg Hospital v. Patterson, 128 N.J. Super 498 (N.J. Super. Ct. 1974); O.G. v. Baum, 490 S.W. 2d 839 (Tex. App. Houston 1st Dist. 1990).
 Prince v. Massachusetts, 321 U.S. 158 (1943).
 Available online at http://www.bloodbook.com/autolog-3.html.
 How Can Blood Save Your Life?, 14 (quoting Dixon B. Kaufman, "A Single-Center Experience of Renal Transplantation in Thirteen Jehovah Witnesses," Transplantation 45 (6 June 1988): 1046.
 Kaufman, "A Single-Center Experience of Renal Transplantation in Thirteen Jehovah Witnesses," 1046.
 See http://www.sangart.com/background.
 See http://www.sangart.com/company/history.php; see also http://www.ajwrb.org.
 "Questions from Readers," The Watchtower (15 October 1992) ("It would be right, of course, to avoid products that listed things such as blood, blood plasma, plasma, globin [or globulin] protein, or hemoglobin [or globin] iron."); see http://www.ajwrb.org/basics/hemopure.shtml.
 "Questions from Readers," The Watchtower (15 June 2000): 29-30, ("Other Christians decide differently. They too refuse transfusions of whole blood, red cells, white cells, platelets, or plasma. Yet, they might allow a physician to treat them with a faction derived from the primary components.") See http://www.jwfiles.com/blood-WT6-15-00.htm.
 See http://www.ajwrb.org/basics/hemopure.shtml ("According to a 24 September 2000 article in the Sacramento Bee, a patient was recently transfused with Hemopure®, a highly purified oxygen-carrying hemoglobin solution made from fractionated bovine (cow) blood and manufactured by Biopure Corporation. Dorsey Griffith, a medical writer for the Bee, states that Gregory Brown, a representative from the Jehovah's Witnesses Hospital Liaison Committee, approved the use of the oxygen-carrying solution that was transfused into the patient, Jose Orduño. The article notes: 'When Orduño woke up from his drug-induced slumber, about a month after the ordeal began, Angelica was there His sister told him about the accident and how he almost died, and about the drug made from cow blood that had saved his life.'").
 "Be Guided by the Living God," The Watchtower (15 June 2004): 19, 21 ("Decades ago Jehovah's Witnesses made their stand clear. For example . . . supplied an article to The Journal of the American Medical Association . . . 'While these verses are not stated in medical terms, Witnesses view them as ruling out transfusion of whole blood, packed RBCs [red blood cells], and plasma, as well as WBC [white blood cell] and platelet administration. . . Witnesses' religious understanding does not absolutely prohibit the use of [fractions] such as albumin, immune globulins, and hemophiliac. . . Since 1981, many fractions have been isolated . . . For the benefit of current readers, the [June 15, 2000 Watchtower] is reprinted on pp. 29-31 of this magazine. It provides details and reasoning, yet you will see that what it says agrees with the basics presented in 1981.").
 "Be Guided by the Living God," 22 ("As to taking of blood factions, some have thought, 'This is a matter of conscience, so it doesn't make any difference.' That is faulty reasoning. The fact something is a matter of conscience does not mean that it is inconsequential. It can be very serious. One reason is that it can affect individuals whose conscience differs from ours . . . A Christian ought to be concerned about not 'wounding consciences that are weak.' If he stumbles others, he could 'ruin his brother for whose sake Christ died' and be sinning against Christ. Hence, while issues about blood factions are for personal decision, those decisions should be taken very seriously.").
 "Be Guided by the Living God," 23 ("Some have concluded that such minute fractions are in effect, no longer blood and hence are not covered by the command 'to abstain from blood.").
 "Most Dangerous Substance," The Watchtower (15 July 1990): 30.
 See http://www.ajwrb.org/index.shtml.
 "Be Guided by the Living God," 21.
 See http://www.ajwrb.org/links/index.shtml.
 American Red Cross Campaign Slogan ("Vast quantities of blood must be donated by non Jehovah's Witnesses to provide all of the blood fractions and medicines used by Jehovah's Witnesses and their children. Please help replenish the supply - give blood."), available online at: http://www.ajwrb.org/links/index.shtml.
 Unknown Author, http://www.ajwrb.org/forbidden.shtml ("Here is an analogy: It's like saying, "see that truck over there, it's stolen and you can't buy it but if someone dismantles it, it's not a truck anymore, it's truck parts and you can buy what you want. However, the engine, the transmission, the radio and the disc brakes are special. They are the 'primary' components of the truck (i.e. the red cells, white cells, platelets and plasma). You can't have these 'primary' components unless you first completely dismantle them. If you do that you can buy them too.").
 The Watchtower 640 (15 October 1959) ("Consequently, the removal of one's blood, storing it and later putting it back into the same person would beg a violation of the Scriptural principles that govern the handling of blood if the blood were stored, even for a brief period of time, this would be a violation of the Scriptures.") available online at: http://www.ajwrb.org/watchtower/data1.shtml; see also Blood, Medicine, and the Law of God (Watchtower and Bible Tract Society of Pennsylvania 1961), 14-15 ("Mature Christians . . . are not going to feel that if they have some of their own blood stored for transfusion, it is going to be more acceptable than the blood of another person."); The Watchtower 30 (15 June 1978); Questions from Readers; The Watchtower 30 (1 March 1989).
 The Watchtower, 30 (15 June 1978) ("So, if medical personnel suggest that a Christian is not without guidance from the Bible . . . removed blood was to be 'poured out on the ground as water' to show that is was for God and not to sustain the life of some earthly creature. (Deut. 12:24)"); The Watchtower, 30 (1 March 1989) ("We read that when a hunter killed an animal for food, 'he must in that case pour its blood out and cover it with dust.' (Leviticus 17:13, 14; Deuteronomy 12:22-24) So the blood was not to be used for nutrition or otherwise.").
 "Watching the World," Awake! 29, 30 (8 April 1972) ("Men of science are constantly developing new methods for performing surgical operations. The Journal of the American Medical Association, dated November 15, 1971, described a procedure for open-heart surgery that employs "sever hemodilution." Early in the operation a large quantity of blood is drawn off into a plastic blood bag. Though the bag is left connected to the patient by a tube, the removed and stored blood is no longer circulating in the patient's system. It is replaced with a plasma volume expander, which dilutes the blood remaining in the veins and which gradually dissipates during the operative procedure. Near the conclusion of the operation the blood storage bag is elevated, and the stored blood is reinfused into the patient . . . These techniques are noteworthy to Christians, since they run counter to God's Word. The Bible shows that blood is not to be taken out of a body, stored and then later reused."); available online at: http://www.ajwrb.org/watchtower/data1.shtml.
 Awake! 16 (22 March 1983) (quoting from Italian medical journal Tempo Medico (December 1980) ("It is with this in mind, and not just to honor the requests of Jehovah's Witnesses, that Denton Cooley [of Houston, Texas] has performed open-heart operations now for over seven years, limiting transfusions wherever possible by substituting hemodilution, diluting the patient's blood with a glucose and heparin solution. If this method has given excellent results since then . . . one wonders why it has not been extended to present-day surgery.") available online at: http://www.ajwrb.org/watchtower/data1.shtml; "Questions from Readers," The Watchtower 30, 31 (15 October 2000) ("For example, during certain surgical procedures, some blood may be diverted from the body in a process called hemodilution. The blood remaining in the patient is diluted. Later, his blood in the external circuit is directed back into him, thus bringing his blood count closer to normal . . . blood may be directed to a machine that temporarily carries on a function normally handled by body organs . . . The blood from the machine is then returned to the patient . . . The details may vary, and the new procedures, treatments, and tests will certainly be developed. It is not our place to analyze each variation and render a decision. A Christian must decide for himself how his own blood will be handled in the course of a medical procedure, medical test, or current therapy.").
 "Questions from Readers," The Watchtower 31 (15 October 2000).
 "Questions from Readers," The Watchtower 30 (15 October 2000) ("Occasionally, a doctor will urge a patient to deposit his own blood weeks before surgery (preoperative autologous blood donation, or PAD) so that if the need arises, he could transfuse the patient with his own stored blood. However, such collecting, storing, and transfusing of blood directly contradicts what is said in Leviticus and Deuteronomy. Blood is not to be stored; it is to be poured out returned to God, as it were . . . Jehovah's Witnesses respect the principles God included in [the Mosaic Law], and they are determined to 'abstain from blood.' Hence, we do not donate blood, nor do we store for transfusion our blood that should be 'poured out.' That practice conflicts with God's law.").
 Frazee v. Illinois Dept. of Unemployment Security, 489 U.S. 829 (1989); United States v. Seeger, 163 (1965).