Another critical barrier to access is discrimination by state laws or fertility clinics. Coverage in five of the states with insurance mandates 12 is only available to married couples, and four of these states 13 mandate use of the husband’s sperm, eliminating the possibility of donor sperm. Some fertility clinics only offer services to married couples as well. The American Society for Reproductive Medicine reports that fertility clinics vary in their willingness to treat single women, single men, lesbian couples, and gay male couples. 14 The Benitez case, currently15 before the California Supreme Court, involves a woman who was denied infertility treatment.