The "Humanae Vitae," meaning "Of Human Life" and subtitled "On the Regulation of Birth," was an encyclical promulgated in Rome, Italy, on 25 July 1968 by Pope Paul VI. This encyclical defended and reiterated the Roman Catholic Church's stance on family planning and reproductive issues such as abortion, sterilization, and contraception. The document continues to have a controversial reputation today, as its statements regarding birth control strike many Catholics as unreasonable.

In 2001, the Supreme Court of New Jersey decided a dispute between a divorced couple over cryopreserved preembryos created through in vitro fertilization (IVF) during the coupleÕs marriage. The former wife (J.B.) wanted the preembryos destroyed, while her former husband (M.B.) wanted them to be used for future implantation attempts, such as by an infertile couple. In J.B. v. M.B. (2001), the court declined to force J.B. to become a parent against her will, concluding that doing so would violate state public policy. Instead, the Supreme Court of New Jersey decided that agreements directing the allocation of cryopreserved preembryos will be enforced, unless one party changes his or her mind prior to the preembryosÕ use or destruction. Should a party revoke an earlier decision about the preembryos, New Jersey courts should weigh the partiesÕ interests with special weight given to an individualÕs right to not procreate.