On 29 June 1988, in Bowen v. Kendrick, the US Supreme Court ruled in a five-to-four decision that the 1981 Adolescent Family Life Act, or AFLA, was constitutional. Under AFLA, the US government could distribute federal funding for abstinence-only sexual education programs, oftentimes given to groups with religious affiliations. As a federal taxpayer, Chan Kendrick challenged the constitutionality of AFLA, claiming it violated the separation of church and state. The Supreme Court found that although AFLA funded programs that aligned with certain religious ideologies, it was constitutional because it did not encourage government involvement in religion, and it held a valid secular purpose in seeking to prevent adolescent pregnancy and premarital sexual relations. By upholding AFLA, Bowen v. Kendrick enabled the US government to continue funding abstinence-only education, which researchers have found to be ineffective.

The 1981 Adolescent Family Life Act, or AFLA, is a US federal law that provides federal funding to public and nonprofit private organizations to counsel adolescents to abstain from sex until marriage. AFLA was included under the Omnibus Reconciliation Act of 1981, which the US Congress signed into law that same year. Through the AFLA, the US Department of Health and Human Services, or HHS, funded a variety of sex education programs for adolescents to address the social and economic ramifications associated with pregnancy and childbirth among unmarried adolescents. AFLA received several criticisms for directly emphasizing and funding abstinence-only education programs from religious organizations. However, when US citizen Chan Kendrick brought the case Bowen v. Kendrick before the Supreme Court in 1988, the Court upheld that AFLA was constitutional. Although numerous evaluations have shown minimal scientific evidence supporting abstinence-only education, as of 2020, the federal government still provides funding for such programs through AFLA.

On 23 April 2008, the US Government Accountability Office, or GAO, released a report titled, “Abstinence Education: Assessing the Accuracy and Effectiveness of Federally Funded Programs,” hereafter “Abstinence Education,” in which it investigated the scientific accuracy and effectiveness of abstinence-only education programs sanctioned by individual states and the US Department of Health and Human Services, or HHS. GAO is a government agency whose role is to examine the use of public funds, evaluate federal programs and activities, and provide nonpartisan support to the US Congress. In “Abstinence Education,” GAO found that as of August 2006, a variety of factors in such programs, such as inaccurate medical information, contributed to overall conclusions that abstinence-until-marriage programs were unsuccessful at reducing the rates of adolescent pregnancy. In “Abstinence Education,” GAO recommends that HHS implement procedures to better assure the accuracy of educational materials used in abstinence programs and to set standards that measure the effectiveness of those programs.