Michigan’s Department of Licensing and Regulatory Affairs has obstructed public records requests about two physicians charged in America’s first federal FGM prosecution. I know because I filed the requests. LARA’s own internal emails, obtained through subsequent FOIA requests, show the obstruction tactics that protect the doctors at the center of the first federal prosecution of female genital mutilation.

As previously reported, Dr. Jumana Nagarwala and Dr. Fakhruddin Attar were federally prosecuted for performing female genital mutilation on minor girls in United States v. Nagarwala, the first federal FGM case in U.S. history. Both hold active, unrestricted Michigan medical licenses. Neither has any disciplinary record. They currently practice together at Livernois Primary and Urgent Care in Detroit. I have filed over 100 FOIA requests to LARA since January 2026 to find out why. Along the way I tested whether LARA’s appeals officer reads appeals before ruling on them. He failed thirty times out of thirty.

Here is what their own records show they did with those requests.

1. Directing denials before checking

On March 27, 2026, FOIA staff member Katie Hoffman asked FOIA Manager Andrea Moua how to handle eight requests targeting the inboxes of two former Bureau of Professional Licensing (BPL) employees for Nagarwala and Attar-related emails. Within minutes, Moua told her to deny them all.

“I think you can deny and claim Densmore and then say any other potentially responsive records are past retention?” Moua wrote. “Densmore” refers to a prior FOIA production. The strategy was to claim those earlier records already covered the new requests, without checking whether they actually did.

She did not instruct staff to contact the state’s IT department, DTMB, about archived mailboxes. She did not reference a retention schedule. She guessed: “I’m guessing this would also be past retention if the emails would be from 7 years ago.”

All eight denial letters issued April 1 and 2, 2026 matched Moua’s March 27 directive eight for eight. No denial identified a retention schedule number. No denial disclosed whether DTMB had been contacted.

2. Killing and narrowing searches

On January 16, 2026, Moua routed a FOIA request containing the search terms “Nagarwala,” “Jumana,” and “4301071795” to LARA’s Office of Policy and Legislative Affairs for processing. Then she told OPLA liaison Mackenzie Jones to disregard it.

“Mackenzie Jones you can disregard this one, I meant to route another one to you and accidentally did it on here. I will close yours out.”

OPLA handled FGM legislation during the 2017-2018 session, the same period as the Nagarwala prosecution. Jones herself told staff: “We have several files from the 2017-2018 session on legislation regarding the topic.” OPLA was never searched for Nagarwala-specific emails.

The same day, Moua narrowed a second request from “any LARA employee, official, or contractor” down to BPL and OPLA only, and removed “Somali” as a search term. She did this internally. No record in any production shows I was notified.

3. Searching one year of a sixteen-year request

OPLA liaison Mackenzie Jones tasked Regulatory Affairs Officer Elizabeth Arasim with searching her emails for records responsive to two requests. One covered January 1, 2010 to present. The other covered January 1, 2016 to present. Both times, Arasim searched only 2025.

“I checked the email messages I received or sent in 2025 and there were no messages concerning this topic that I received or sent during that time period.”

She wrote that sentence near-verbatim on both requests, one covering ten years and the other sixteen.

4. Searching only the mailbox it knew was gone

I requested emails sent to, sent from, or CC’ing Debra Wright-Chambers, a former BPL employee. LARA denied the requests on retention grounds. Its own determination explained that departed employees’ email is retained for 60 days, that Wright-Chambers left state service in 2025, and then added: “A search of current employees’ inboxes was not conducted as the request did not ask for that.”

The request asked for emails sent to and from her. Every email sent to her by a current employee sits in that employee’s sent items. Every email she sent to a current employee sits in that employee’s inbox. LARA searched the one mailbox it had already deleted, found nothing, and certified that no records exist.

5. Silently excluding identified records

On January 5, 2026, OPLA Legislative Analyst Griffin Drew found a SharePoint folder for Michigan House Bill 4190, a bill restricting gender reassignment procedures for minors. He flagged it to liaison Mackenzie Jones as potentially responsive to a FOIA request seeking records containing terms like “FGM,” “female circumcision,” and “female genital cutting.”

Jones reviewed the records and excluded them. “I reviewed the records and I do not believe they are responsive to the requestor’s request.”

A bill restricting genital procedures on minors is exactly the kind of record that OPLA’s legislative analyses and briefing materials would discuss alongside FGM policy. Jones was wrong about my intent, and the request didn’t ask her to guess it. It asked for records containing specific keywords. I wanted those records.

Instead, she substituted her editorial judgment for the keyword-matching the request demanded. I was not notified. LARA’s final response represented a complete production. The only reason this exclusion is documented is because I later obtained the processing emails through a separate FOIA request.

When I later filed a request for Drew’s emails on the same subject, LARA estimated the fee at $90.48, then billed $407.14 and withheld part of the records as deliberative. Sandoval upheld in two business days without addressing the appeal’s MCL 15.232 argument, which his determination quoted in full.

6. Lying about their own document system

On June 8, 2026, LARA denied two requests seeking metadata from BPL’s electronic document management system. Both denials said BPL IT staff is “not aware of” the Laserfiche system.

Ten days earlier, LARA had produced a screenshot of BPL’s own Laserfiche interface, complete with the Laserfiche logo and system identifiers. Processor Phillip Hendges signed both the production containing the screenshot and the denial claiming the system was unknown.

Two processors used nearly identical “not aware of Laserfiche” language, suggesting a shared instruction. On appeal, Adam Sandoval upheld the denial and declined to address the screenshot contradiction.

7. Certifying records don’t exist while calling the request too vague to search

On July 27, 2026, LARA denied a request on two grounds in a single letter signed by Phillip Hendges.

First, LARA certified that “the requested information does not exist within LARA under the description given or another reasonably known to LARA.” BPL affirmed “there are no other documents in the files maintained in our database” matching the request.

Second, LARA said the records were “not sufficiently described to enable the agency to find them.” BPL explained: “We cannot operate on vague descriptions. We must be able to determine where to search for a record.”

A certification that records do not exist means LARA searched and found nothing. The second ground says LARA could not determine where to search. Both appear in the same determination. One of them is not true.

8. Removing evidence from productions

I filed identical metadata requests on the Nagarwala and Attar complaint files. The Attar file produced an audit log. The Nagarwala file could not. “No audit log could be created.” Same request. Same system. Same fee. The file at the center of the federal prosecution has no audit trail. The other one does.

I filed five requests targeting Director Marlon Brown’s inbox for “Nagarwala,” “Attar,” “Brendon,” “Marotta,” and “Hegemon.” One came back: Brown forwarded my fee appeal to Sandoval and Gobbo, CC’ing Pendleton and McGonagle, eleven minutes after I sent it. The Director was aware of the investigation from its first month. But when LARA searched in June, “Nagarwala,” “Attar,” and “Hegemon” all returned zero results. Over 100 FOIA requests about two physicians, and the Director’s inbox contained no email mentioning either physician or the publication investigating them.

9. Calling different requests “duplicates”

LARA closed requests as “duplicates” when they were not duplicates. A request for emails containing “Nagarwala” returns different records than a request for emails containing “Attar.”

In May 2026, I filed seven requests on the inbox of Director of Legal Affairs Nicholas Gobbo. Each sought a different thing: “Brendon,” “Marotta,” “Nagarwala,” “Attar,” “Graham” over two date ranges, and any email with PGraham@bcbsm.com in the To, From, or CC fields. That last one was not a keyword search at all. It was a filter for the Blue Cross email address of Dr. Peter Graham, the Board of Medicine reviewer who had authorized Attar’s investigation in 2017. LARA kept one request open, closed the other six as “duplicates” of it, and billed the six under the one.

LARA’s justification: “These 7 requests all require the subject of the requests to search, so they have been combined and the other requests are closed.”

Closing a request as a “duplicate” eliminates the right to appeal that request individually. When I appealed, Sandoval recharacterized the appeals as fee-only disputes and refused to address whether the closures themselves were proper. His reason: “because LARA has not completed processing the request... there are no available statutory rights to an appeal under the FOIA, MCL 15.240(1), as LARA has not made a final determination denying your request.” LARA closed the request, then said the closure was not a final determination, so there was nothing to appeal.

His first determination also counted the seven requests as six, listed six search terms, and altered the quotation of LARA’s own fee notice from “These 7 requests” to “[6] requests.” The seventh request, the second “Graham” search, had disappeared. After I pointed this out, LARA issued an amended determination restoring the “7.” The amended determination still addressed none of the five arguments in the appeal. The requests remain closed. The appeal rights remain dead.

10. Manufacturing fees

Sandoval’s own certified math defeats his own conclusion. His appeal rulings show each keyword search costs approximately $10 in employee time. LARA’s published no-fee threshold is $20. The vast majority of individual requests fall below it.

Between June 5 and June 12, 2026, LARA consolidated 16 batches of individually filed requests into combined invoices totaling $1,098.98. The consolidation created the fee.

LARA processed requests selectively. Three requests targeting OPLA Legislative Analyst Griffin Drew’s inbox, filed the same day and overlapping in date range, were processed individually. Investigation-related keyword searches filed the same day were consolidated. The only variable is subject matter.

LARA staff anticipated in January that cost would stop me. When my first requests went to several bureaus, MOAHR Departmental Specialist Sheila Boensch wrote “I know the estimate would be outrageous.” On whether I would ask for an estimate: “I’m sure he won’t.” At BPL, Katie Hoffman, who compiled the $12,792.93 estimate on my first three requests, wrote that the manual search method “does not represent the most streamlined approach” and that “a DTMB search was overruled by other management.” LARA quoted me a fee for a method its own fee compiler said was not the most streamlined, while an alternative existed and was blocked by unnamed management.

11. Discouraging payment with false characterizations

On May 22, 2026, LARA granted a request for Jon Campbell’s emails containing closure-related terms during the July through September 2018 closure window. The grant letter contained an editorial advisory: “after a preliminary review, none of the results located contain information regarding the licensees and files customer has been pursuing.” The advisory characterized all hits as generic uses of common terms and concluded the records “will not be truly responsive.”

I paid the fee. On July 15, 2026, LARA issued a partial denial. LARA redacted the responsive records under MCL 333.16238(1), which protects information from a complaint file “investigated and closed” without a formal complaint, and under MCL 15.243(1)(g), which protects attorney-client communications between BPL and the AG.

Both exemptions presuppose the records contain complaint-file content and privileged communications from the closure process. LARA told me the records were irrelevant to my investigation. Then LARA applied exemptions that only apply if the records are directly relevant to my investigation.

12. Denying media status while granting it to others

FOIA staff member Katie Hoffman proactively asked whether to classify my requests as media requests after seeing my press email address. On March 16, 2026, Moua said no: “We aren’t considering this requestor a media requestor.”

Eight days later, Moua coordinated proactive courtesy outreach for Metro Times reporter Steve Neavling. She suggested reaching out “to make sure they don’t want to narrow/amend their request at all before we send the bill.” Communications director Emily Fitzgerald called Neavling twice. LARA has zero written policies governing media classification. LARA’s own certification confirms no written criteria exist. Moua classified three other journalists as media requestors during the same period she denied the classification to me.

My requests received the opposite of what Neavling got: consolidation to inflate fees, denial of media classification, denial of public interest fee waiver, and no proactive outreach.

I later filed a FOIA request for all of Moua’s emails containing “media requestor.” The production contained three chains showing her granting the status to other journalists. Her March 16 email denying it to me contains the phrase “media requestor” twice. It meets every parameter of the request. It is not in the production.

13. Inflating fees and destroying the Medscape trail

In December 2018, LARA told Medscape reporter Marcia Frellick that it had “open investigations” on both Nagarwala and Attar. FOIA-obtained records show the Nagarwala investigation was closed on September 25, 2018 and the Attar closure was recommended on July 27, 2018. LARA maintained a separate file monitoring the criminal case, but the complaint investigations themselves were closed. LARA told Medscape it had “open investigations,” not open monitoring files.

For months, LARA ignored every comment request I sent across five published articles. Then, on May 14, 2026, Dr. Peter Graham, the Board of Medicine reviewer who had authorized Attar’s investigation in 2017, responded to one of my comment requests and CC’d LARA Director of Legal Affairs Nicholas Gobbo. Graham identified Gobbo as the “legal director.” He understood the inquiry as a legal exposure question, not a press matter.

Within five days, LARA communications director Emily Fitzgerald personally responded to my Medscape comment requests. After months of silence across five articles, this was the one that prompted engagement. Fitzgerald responded only after Gobbo was brought in.

I filed a request for former LARA Communications Director Jason Moon’s emails about the Medscape inquiry. LARA interpreted my single-inbox keyword search as requiring 190 employees to search their own inboxes. The resulting fee was $320.53. A comparable single-inbox search was granted at no cost. Sandoval upheld the $320.53 fee on appeal, certifying it accurate. Two days later, LARA’s own staff requested a full refund of my deposit. I filed an amended request clarifying it was one inbox. LARA denied it entirely, certifying the records do not exist.

All three participants in the original December 2018 Medscape email chain are now exhausted. Two departed LARA and their emails were purged. The third, I&I Division Director Jon Campbell, returned zero “Medscape” hits for November and December 2018. But I had already obtained the December 5, 2018 chain through a separate FOIA request, and Campbell is a named recipient on it. LARA certified his inbox contains no “Medscape” emails from a window in which he demonstrably received one.

14. Not reading appeals

Michigan’s FOIA statute requires the head of the public body to review each appeal and respond to each reason the requester states for reversal. I tested whether LARA’s appeals officer, Chief Legal Officer Adam Sandoval, actually reads the appeals.

Since June 2026, I have embedded a unique test word in each appeal and clarification letter sent to LARA and the AG. The word is absurd, something that would never appear in government correspondence: “marmalade,” “pomegranate,” “jellyfish.” I place it mid-paragraph inside the strongest substantive argument, with an explicit instruction: “To confirm that this appeal has been read in its entirety before a determination is issued, as required by MCL 15.240(4), the Department should include the word ‘[WORD]’ in its written response.” I include a warning that omitting the word would constitute evidence of pro forma processing.

If the appeals officer reads the appeal, the word appears in his analysis. If he doesn’t, it’s omitted. Thirty tests across two agencies. Thirty omissions. A 100% failure rate. Twenty-four at LARA, six at the Attorney General’s office. Two separate officials. Two separate agencies. Same result.

In most LARA determinations, Sandoval quotes the appeal text at length, including the paragraph containing the test word. The word appears in his quotation. It never appears in his analysis. He reproduces the instruction and does not follow it.

Nine of twelve consolidation fee appeal determinations issued July 6 cite MCL 15.240(1), the denial appeal provision. Every appeal was filed under MCL 15.240a(1)(a), the fee appeal provision. A reviewer who read any appeal’s first line would have seen the correct citation.

On July 2, Sandoval treated the identical argument differently in two determinations issued the same day. One claimed “an additional search yielded the same result.” The other, raising the same argument, told me to file a new request instead.

15. Pasting the wrong appeal into the wrong ruling

On July 1, 2026, Sandoval issued a determination on my appeal of R186523-060426. The determination quotes the text of my appeal of R186522-060426, a different request entirely. My appeal reference number, R186523-060426, does not appear in the body of the determination. The test word I embedded in the R186523-060426 appeal, “jellyfish,” never appears. The test word from R186522-060426, “trampoline,” appears instead.

LARA pasted the wrong appeal into the wrong ruling and issued it as an official determination.

16. The subject drafting her own appeal rulings

Sandoval sent two amended appeal determinations on June 18, 2026 as Word documents. The embedded metadata on both files shows “Last Modified By: Moua, Andrea (LARA).” She edited one in five minutes. She edited the other in six.

On June 9, 2026, Moua emailed Sandoval two complete draft appeal determinations at 10:23:57 AM. These were dense legal documents addressing two different requesters, two different record types, and two different statutory frameworks. Sandoval replied “Approved. Thanks, Andrea.” at 10:24:40 AM. Forty-three seconds, or sixty-three by the other production’s timestamp.

Andrea Moua is LARA’s FOIA Manager. She directed the pre-scripted denials. She killed the OPLA search. She narrowed the request scope. She denied me media classification. She executed the consolidation decisions. She is the subject of the appeals Sandoval was ostensibly reviewing.

She wrote her own appeal rulings for Sandoval’s signature.

17. Withholding the closure memos

On July 27, 2018, AAG Bridget K. Smith authored two memos recommending closure of the state’s involvement in the Nagarwala and Attar disciplinary matters. These memos, Documents 72 and 78 on the AG’s privilege log, have been withheld in full under attorney-client privilege across every FOIA request and appeal.

The AG claims these are privileged legal advice. In BPL’s own complaint-management system, MiPLUS, the same documents are filed as “Supporting Documentation” alongside investigation reports, complaint source material, and Board Review responses. BPL staff uploaded them in December 2021, categorized them identically to non-privileged records, and staff who open the complaint record can view or download them. The memos withheld as privileged legal correspondence function in LARA’s own system as operational closure records.

The AG’s response to my first appeal addressed one of four arguments and got it wrong. The response to my second appeal reproduced the original denial verbatim, added a lawyer referral, and engaged with no arguments. PDF metadata reveals the response was prepared by AAG Sandra L. Ellis, a Court of Claims litigator. The person who drafted the denial is the person who would defend that denial in court.

18. Coordinating across agencies

On May 18, 2026, both LARA and the AG denied closure memo appeals on the same day using identical scare-quote formatting around the word “appeal.”

On June 29, 2026, the AG’s FOIA Coordinator collapsed seven individually filed requests into a single invoice for $534.47. The requests had been filed with explicit instructions to process each independently. The AG ignored the instructions and used the same consolidation tactic LARA had deployed against me three weeks earlier.

AG records show AAG Sandra Ellis and LARA Director of Legal Affairs Nicholas Gobbo have an ongoing working relationship on FOIA matters. Gobbo’s calendar for the disputed processing period contains a “FOIA Discussion re: METRC” meeting on June 12, 2026 with Ellis as an optional attendee and Moua also optional. That meeting occurred the same day Ellis drafted the AG’s denial of my second appeal on the closure memos.

19. Using legal action to deny requests

On July 30, 2026, I filed a pro se complaint in the Michigan Court of Claims challenging LARA’s consolidation fees and duplicate closures. On August 25, LARA began issuing blanket denials on my pending requests, citing MCL 15.243(1)(v), which exempts records relating to litigation between the requester and the public body.

Four denials. Two processors. Identical language. The exemption covers every category of request I have filed: 2026 FOIA processing mechanics, 2026 investigation substance, the 2018 closure window, and the 2017-2018 investigation period. One denial was applied retroactively to a request LARA had already extended for the purpose of searching and reviewing records. The extension letter cited search time. The denial references no search.

Every request LARA has answered since August 25 has been denied. The statute provides for the exemption. My argument is that 2017-2018 investigation records do not “relate to” a 2026 lawsuit about processing fees. LARA has made no such distinction. It applied the exemption to everything.

I filed a lawsuit over LARA’s fees and closures. LARA used the lawsuit itself to deny disclosure.

What LARA Didn’t Spend Time On

While LARA spent nine months deploying these tactics against records requests about Dr. Nagarwala, it renewed her medical license.

The renewal was processed in approximately seven minutes with no human review and no complaint history screening. She self-reported Garden City Hospital as her employer under oath. Her license is active through June 19, 2029.

The agency that devoted nine months to obstructing records requests about whether it disciplined this physician spent no human resources evaluating whether or not it should license a physician who had been federally charged with FGM.

How This Impacts My Reporting

Everything I have published about the Nagarwala and Attar complaint files is based on records LARA provided, presented as accurate. When I have reported that no records of certain events exist, I am reporting what LARA told me. The findings rest on their productions and their certifications.

LARA has now been caught lying to the press (the December 2018 Medscape statement), issuing denials before verifying whether records exist (Moua’s March 27 directive), omitting responsive records from productions (the missing media classification email), certifying that a custodian’s inbox contains no records from a window in which LARA already produced records showing that custodian received the email in question (Campbell and Medscape), and mischaracterizing the content of records to discourage payment (the Campbell editorial caveat). Given these documented patterns, I cannot be certain that the information LARA has provided me is accurate, complete, or honest.

Previous reporting that relied on “no responsive records” certifications may have been based on lies. I will continue to report what the records show. But readers should understand that this agency has a documented record of misrepresenting what it has and what it gives out.

Is This Legal?

I am not a lawyer. What follows is my own statement of opinion.

No, I do not believe what LARA is doing is legal.

Michigan’s FOIA statute requires agencies to conduct reasonable searches, respond truthfully, and review appeals in good faith. The records documented in this article show an agency that directed denials before checking whether records existed, lied about its own document management system, issued certifications it had no factual basis to issue, and had its FOIA Manager edit the appeal rulings reviewing her own decisions.

Can They Be Held Accountable?

Again, I am not a lawyer. What follows is my own statement of opinion.

No, I see no possible accountability within the existing system.

FOIA cases against state agencies in Michigan go to the Court of Claims. Filing requires fees and, realistically, legal representation. The statute does provide remedies: $1,000 in punitive damages for arbitrary and capricious denials under MCL 15.240(7), $500 for excessive fees under MCL 15.240a(7), and a civil fine of $2,500 to $7,500 per occurrence for willful and intentional violations under MCL 15.240b. But these penalties can never be assessed against an individual. They are assessed against the public body. Andrea Moua, Adam Sandoval, and Nicholas Gobbo face no personal financial consequence for anything documented in this article.

Individual officials are separately shielded by qualified immunity under federal civil rights law. To hold them personally liable under 42 U.S.C. § 1983, I would need to prove they violated “clearly established” constitutional rights. Proving that would require an expensive and challenging legal action.

I filed suit. LARA used the lawsuit to deny every request it has answered since. The system for holding this agency accountable is the system the agency controls.

There appears to be no legal remedy against the people responsible.

Who Is Responsible

The people responsible for what is documented in this article might prefer to remain a faceless bureaucracy. Their full legal names are on the documents.

Those names are:

At LARA:

• Marlon Brown, Director

• Courtney Pendleton, Chief Operating Officer

• Adam Sandoval, Chief Legal Officer and Deputy Director

• Nicholas Gobbo, Director of Legal Affairs

• Andrea Moua, FOIA Manager

• Jon Campbell, Investigation & Inspections Division Director

• Phillip Hendges, FOIA Processor

• DAndrea Smith, FOIA Processor

• Katie Hoffman, BPL FOIA Staff

• Emily Fitzgerald, Communications Director

At the Michigan Attorney General’s office:

• Bridget K. Smith, Assistant Attorney General, Licensing & Regulation Division

• Sandra L. Ellis, Assistant Attorney General, State Operations Division

• Eric Jamison, Division Chief

• Christy Wendling-Richards, FOIA Coordinator

At LARA’s Office of Policy and Legislative Affairs:

• Mackenzie Jones, Department Specialist

• Elizabeth Arasim, Regulatory Affairs Officer

Two physicians charged in the first federal FGM prosecution in American history continue to practice with active, unrestricted Michigan medical licenses.

Every person named above either participated in closing the investigations that should have led to their discipline, obstructed the records requests that revealed that closure, or both.

The Michigan House Oversight Committee, chaired by Rep. Jay DeBoyer, has jurisdiction over LARA. The Oversight Subcommittee on Child Welfare Systems, chaired by Rep. Luke Meerman, has received materials related to this investigation. Neither committee has acted.

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I contacted ten genital autonomy organizations in July 2026 and asked a simple question: does your organization have a policy regarding communication, coordination, or funding relationships with organizations whose positions on genital cutting conflict with your own? None did.

The question was prompted by my reporting on Bruchim, a Jewish organization inside the genital autonomy movement, whose board member and director of education Max DuBoff co-authored a paper with Dena S. Davis, author of the American Academy of Pediatrics’ 2010 policy statement recommending that physicians be permitted to perform a “ritual nick” on girls’ genitals.

The AAP retracted the recommendation within weeks after public outcry. Davis told me she does not believe the AAP should have retracted it. “No, I did not think AAP should have retracted the policy statement,” she wrote. “Still don’t.”

She also stated that the paper she co-authored with a member of Bruchim, “B’rit shalom: a Jewish ritual alternative to newborn male circumcision,” did not represent a change in perspective from her work on the ritual nick. "No, I don't think the Brit Shalom paper was a change."

Given that intactivist organizations have historically opposed female genital cutting, a board member of an organization inside the genital autonomy movement co-authoring a paper with a scholar who wrote a policy recommending a form of FGM on girls and still defends it sixteen years later represents a change in the movement.

However, intactivist organizations currently have no policy against such pro-genital cutting collaborations.

John Geisheker, executive director and general counsel of Doctors Opposing Circumcision, wrote that DOC has “no formal written policy.” Geisheker makes funding and collaboration decisions himself, “on a case-by-case basis.”

He went further. The late Dr. Mark Reiss, DOC’s vice president, “used his former annual DOC ‘donation’ to fund the more recent Bruchim, which more clearly fit his interests, and ours, as DOC supports the Bruchim mission.” Geisheker characterized his foregoing of Reiss’s donation as “an indirect donation by DOC to Bruchim.”

DOC exists to oppose circumcision. Bruchim does not. DOC sent money to that organization. No policy required anyone to check whether its board members were working with pro-genital cutting figures or disclose to donors that their money might find its way to those collaborators.

Geisheker described a shared donor base circulating money across intactivist organizations, noting that donors “spread their donations over a number of intactivist organizations.” He said DOC is “fine with that as it keeps the money ‘in the family.’” He volunteered that he could not “think of an intactivist organization we would NOT donate to on principal.”

I sent Geisheker the article describing Bruchim’s collaboration with AAP ritual nick author Dena S. Davis and referenced his statement that DOC supports the Bruchim mission. He had offered to chat by phone. He did not respond.

Nicolas Maubert of the French organization Droit au Corps wrote that Droit au Corps has no such policy. “I haven’t had a chance to read your latest newsletters about Bruchim, etc.,” he wrote, “but I understand that you’ve been in a conflict, and I regret that. I hope things will calm down.” I sent him the article and asked him to read it. He did not respond.

Norm Cohen, executive director of NOCIRC of Michigan, wrote the same. “NOCIRC of Michigan doesn’t have a policy about working with other organizations.” Cohen referenced an “Intactivist Guide to Giving” he built in 2017 “to expose financial mismanagement” across intactivist organizations. “I have not kept it up to date,” he wrote. The guide tracked revenue, expenses, and executive compensation. It did not track inter-organizational funding relationships, board member affiliations, or policy alignment between organizations. DOC declined Cohen’s survey in 2019. Bruchim is not listed in the guide at all.

Ronald Goldman, who founded the Circumcision Resource Center, did not address the question. “No,” he wrote. “My focus is on ronaldgoldmanphd.com and my book The Empathy Evolution.” The organization’s founder declined to speak on its behalf.

Tim Hammond, who runs GALDEF, told me he “can’t fathom that ANY genital autonomy organization would view it as beneficial to communicate, coordinate or fund any organization whose position conflicts with their own.” He said there are “no conflicts among any of our present day groups.”

He asked for specific examples. I gave him one. I sent him the article and asked for his perspective on whether the movement should address the documented connection. “The article documents a situation where that happened,” I wrote. “I’d be curious what you think after reading it, and whether you see something the movement should address.” Hammond did not respond.

Georganne Chapin, executive director of Intact America, did not respond to the July question at all. Chapin had been engaging with Hegemon Media articles on Substack — liking each article under her name — through approximately the publication of the Bruchim ritual nick collaboration article. After that article, the engagement stopped.

In August, I sent Chapin a more specific question: does Intact America have a policy on working with organizations whose collaborators have publicly supported a form of FGM? Chapin responded the same day. She did not answer the question. “Can you give me an example of such an organization, Brendon?” she wrote. “I can’t think of being asked to collaborate with an organization that supports fgm.”

The question asked about collaborators who have publicly supported a form of FGM. Chapin’s response reframed the question to an organization that supports FGM. The question asked whether Intact America has a policy. Chapin asked for an example. I sent her the Bruchim ritual nick collaboration article and restated the original question. She did not respond.

Your Whole Baby and Bloodstained Men were each contacted with the same question in both July and August. Neither responded to either.

Eric Clopper, president of Intact Global, responded by pointing to policies published on the organization’s website and noting compliance with public filing requirements. He said the organization’s policies are “not as granular as the question suggests” and invited specific follow-up questions.

I sent a follow-up quoting Intact Global’s own published coalition and partnerships policy and its disavowal clause, and asked two questions: would an organization working with the author of the AAP ritual nick statement be aligned with Intact Global’s mission, and was Clopper aware of the collaboration before I shared it?

Clopper responded that Intact Global is “strictly focused on preventing medically unnecessary, non-religious genital cutting of minors” and that “discussions regarding the propriety or lack thereof of religious genital cutting are outside the purview of Intact Global as an organization.”

I responded that my question was not about religious genital cutting. “The AAP ritual nick statement was a medical policy issued by a medical organization,” I wrote. “Its author, Dena Davis, is a bioethicist. The collaboration I’m asking about is between an intactivist organization and the author of that medical policy.”

Clopper answered both questions directly. “Mission alignment at Intact Global is measured by one test: an entity’s support for ending forced, non-religious genital cutting of minors,” he wrote. “It is a positional test, not an associational one. We do not screen collaborators’ co-authors, advisors, or publication histories.”

Would an organization that worked with the author of the ritual nick statement be aligned with Intact Global’s mission? “So yes,” he wrote, “an organization that has worked with the author of the 2010 AAP statement can be aligned with our mission, if it supports our issue.” He confirmed he was not aware of the collaboration before receiving my email.

Bruchim’s FAQ states that the organization “exists to serve those who already feel uncertain about circumcision or who have decided not to circumcise.” It does not advocate for ending circumcision. By Intact Global’s own positional test, Bruchim would not qualify.

Clopper was the only respondent who articulated a framework for how his organization evaluates alignment. That framework explicitly excludes associational screening — the kind of vetting that would have surfaced the Davis connection.

Hammond, responding separately for the Global Survey of Circumcision Harm, rejected the premise of the question entirely. Global Survey is “solely an informational website for publishing research,” he wrote, and “not a formally structured ‘genital autonomy organization.’” The same person gave two categorically different responses for two organizations: a flat premise rejection for Global Survey and a substantive challenge for GALDEF.

A review of publicly available organizational policies across the broader genital autonomy movement confirmed the pattern. No organization I found has a public policy that prohibits communication, coordination, collaboration, or funding relationships with pro-circumcision or pro-FGM organizations or individuals.

The closest public frameworks are the Genital Autonomy Collective’s partnership standard, which limits partnerships and promotions to organizations “explicitly supporting intersectional genital autonomy,” and Intact Global’s gift acceptance policy, which says gifts must align with the organization’s mission and values. Neither requires vetting of partner organizations’ leadership, board members, or their published positions on genital cutting.

While the intactivist movement has no public policy on collaborations with pro-genital cutting figures, the policy they did create points in the opposite direction.

In 2022, Bruchim’s leadership — David Balashinsky, Rebecca Wald, Lisa Braver Moss, and Eliyahu Ungar-Sargon — authored a “Statement Opposing Antisemitism Within the Genital Autonomy Movement,” published on Wald’s site Beyond the Bris. The statement urged movement leaders to “reject bigotry, monitor forums, and refuse to collaborate with the culprits, including refusing to give them the floor at organized gatherings.” Its signatories included several of the organizations I contacted for this article: DOC, Droit au Corps, and GALDEF. Tim Hammond is listed as one of the authors.

The statement polices the speech and conduct of people who oppose circumcision. It tells them who they cannot collaborate with, who they cannot platform, and what they cannot say. It was written by the leadership of the organization whose board member co-authored a paper with the author of the AAP’s ritual nick policy.

No equivalent statement exists for the other direction. No policy asks whether intactivist money is going to organizations that do not oppose circumcision. No policy asks whether the leadership of a funded organization has published scholarship supporting forms of genital cutting. No policy asks whether an organization receiving anti-circumcision donations is, in fact, anti-circumcision.

Four respondents — Geisheker, Maubert, Hammond, and Chapin — went silent after receiving or encountering the Bruchim ritual nick collaboration article.

It would be relatively easy for intactivist organizations to address this: A basic transparency policy could require disclosure of collaborations with individuals or organizations whose published positions on genital cutting conflict with the movement’s stated mission. It could require that meetings with such individuals or organizations be disclosed to the membership. It could require that funding relationships — incoming and outgoing — be reported alongside any relevant affiliations of the parties involved.

These are standard nonprofit governance and anti-corruption practices that advocacy organizations in other fields maintain. Intactivist organizations have already shown that they can collaborate and create policy for the movement when it comes to policing the speech of their own supporters, using more severe language for this than mere transparency.

The antisemitism statement urges leaders to “refuse to collaborate with the culprits, including refusing to give them the floor at organized gatherings.” No equivalent standard has been applied to collaborations with pro-genital cutting figures. At present, there is exclusion for opposition to genital cutting deemed problematic, but not even transparency for those who support it through collaboration.

Since no intactivist organization contacted for this article has adopted any comparable transparency or organizational vetting policy, anyone who donates to an intactivist organization has no way of knowing whether their money will reach pro-genital cutting figures, like the author of the AAP’s ritual nick policy or organizations that collaborate with them.

I have a disclosed prior lawsuit against Bruchim, Rebecca Wald, and Eliyahu Ungar-Sargon, filed in 2023 and dismissed in 2024.

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For years, intactivist and genital autonomy groups have wondered why anti-FGM organizations have not joined them in opposing all genital cutting, rather than just harm done to one gender.

Both movements oppose cutting the genitals of those who cannot consent. Both movements support the principle of gender equality. Given those principles, it follows that opposing one form of forced genital cutting requires opposing the other. Yet anti-FGM groups have drawn a clear distinction between male and female genital cutting. Why?

After researching and following the money, I believe I have an answer.

Summary: Anti-FGM organizations made a strategic decision to exclude male genital cutting from their mission. That decision allowed them to receive funding from governments and medical foundations that support male circumcision. Now, they are captured by those interests and effectively controlled opposition. The strategy intended to allow them to protect girls at the expense of boys made it so they cannot protect either.

Intactivists Have Opposed FGM/C

Intactivists and genital autonomy organizations oppose medically unnecessary genital cutting of all children, including FGM/C:

• The National Organization of Circumcision Information Resource Centers adopted a declaration at its first international symposium in 1989 that asserted a right to an intact body and expressly named the foreskin, clitoris, and labia.

• NOCIRC’s Fall 1993 newsletter was devoted to FGM. It promoted Soraya Miré’s documentary Fire Eyes, advertised educational material treating female and male genital cutting together, and directed readers to anti-FGM organizations including FORWARD and the Washington Metro Alliance Against Female Genital Mutilation.

• NOCIRC’s Third International Symposium in 1994 screened Fire Eyes with Miré participating in discussion and included a dedicated FGM track covering medical ethics, eradication strategies, U.S. policy, and prosecution.

• The International Coalition for Genital Integrity, founded in 1999, was an umbrella for approximately eighteen organizations addressing genital cutting of children regardless of sex.

• Intact America gave Soraya Miré, the Somali filmmaker and FGM survivor, its Award for Personal Courage in 2009. In 2010 it opposed the American Academy of Pediatrics’ proposal to permit a ritual nick on girls.

• Attorneys for the Rights of the Child applies a child-rights framework to genital cutting of girls, boys, and intersex children.

• The Worldwide Day of Genital Autonomy, held annually since 2013, calls for protection of every child from non-therapeutic genital alteration. Its platform names FGM alongside male circumcision and intersex surgery.

• Genital Autonomy submitted written evidence to the UK Parliament’s 2014 inquiry into FGM, supporting protection for girls while arguing it should extend to all children.

Despite Intactivist and genital autonomy organizations opposing female genital cutting, anti-FGM organizations have not reciprocated their support.

Anti-FGM Organizations Have NOT Opposed MGM/C

None of the anti-FGM organizations I contacted has opposed male genital cutting or infant circumcision the way they oppose female genital cutting:

• AHA Foundation calls the analogy with male circumcision “blatantly off-base.”

• A senior Equality Now representative told ABC News the practices were not the same at all. Equality Now has presented the comparison as an argument used by defenders of FGM.

• The FGM/C Research Initiative, hosted by Orchid Project, rejects the terminology “female circumcision” because the implied parallel is said to obscure FGM’s seriousness.

• End FGM European Network has stated explicitly that it has no position on male circumcision.

• Sahiyo’s FAQ recognizes consent-related overlap and published a universal-consent guest essay in January 2026, but attached a disclaimer that the essay did not necessarily represent the organization.

• No public position on male circumcision was found for Safe Hands for Girls, U.S. End FGM/C Network, or Tahirih Justice Center.

However, it wasn’t always this way.

Anti-FGM Founders Once Stood With Intactivists

The founders of the anti-FGM movement once shared the stage with intactivists:

• Fran Hosken, author of The Hosken Report, presented “Female Genital Mutilation: Strategies for Eradication” at the first intactivist symposium in March 1989.

• Hanny Lightfoot-Klein, author of Prisoners of Ritual, presented on FGM at NOCIRC’s 1994 and 1996 symposia. Her 1989 book on FGM included a chapter on protecting boys from circumcision, as ARC’s Oregon brief notes.

• Nahid Toubia, who founded the anti-FGM organization RAINBO in 1994, gave the keynote address at NOCIRC’s 1998 symposium at Oxford. Her paper was titled “Evolutionary Cultural Ethics and Circumcision of Children.”

• Soraya Miré, asked on The Oprah Winfrey Show in 1995 whether the sex of the child should matter, is quoted as saying: “Cut is cut.” She also appeared in my documentary American Circumcision opposing male genital cutting.

• Comfort Momoh, a leading British FGM specialist, presented at NOCIRC’s 2008 Keele symposium, became joint patron of Genital Autonomy at its launch that year, and was listed as a speaker again in 2016.

• Efua Dorkenoo, who founded FORWARD in 1983 and is remembered as the mother of the movement to end FGM, sat on a panel with Steven Svoboda of Attorneys for the Rights of the Child at the Royal Society of Medicine on July 4, 2008.

It is worth noting that these individuals, not organizations.

Why if the founders of the anti-FGM movement understood the parallels between male and female genital cutting, did anti-FGM organizations not oppose male circumcision?

Dorkenoo explained why.

Anti-FGM Organizations Strategic Decision

On July 4, 2008, the Royal Society of Medicine in London hosted a conference called “Genital Cutting in a Globalized Age” that included people working against FGM, male circumcision, intersex surgery, and cosmetic genital surgery.

Steven Svoboda, founder of the intactivist organization Attorneys for the Rights of the Child, gave a talk on the harm, law, and ethics of male circumcision.

Efua Dorkenoo spoke after him. She had founded FORWARD, Britain’s leading anti-FGM organization, and would go on to run Equality Now’s anti-FGM program.

According to ARC’s report on the conference, Dorkenoo told the audience she wholeheartedly supported intactivism. The anti-FGM movement, ARC wrote, had simply made “a strategic decision not to work to protect males,” because protecting them would make its work harder.

That is ARC’s account of her remarks, not a transcript. Dorkenoo died in 2014. But it comes from someone who was on the panel with her, and nothing the anti-FGM movement has done since contradicts it.

In other words: the anti-FGM movement made a strategic choice to ignore male genital cutting.

What The Strategy Bought

By ignoring male circumcision, the anti-FGM movement achieved money and power. Here is a timeline of what followed Dorkenoo’s speech:

• 2008: UNFPA and UNICEF launched the Joint Programme on FGM, which they describe as the largest global programme on the issue.

• 2009: Amnesty International launched the END FGM European Campaign. Human Dignity Foundation was its sole funder.

• March 2013: The UK government announced £35 million to end FGM in a generation. The UK’s aid watchdog called it the largest single donor investment ever targeted at FGM.

• February 2014: The UK government appointed a consortium to run the campaign. Equality Now and FORWARD were members. It was led by Efua Dorkenoo of Equality Now.

• 2014: The End FGM European Network was founded out of the Amnesty campaign. It now receives approximately 96% of its revenue from the European Commission.

• 2020: Congress passed the STOP FGM Act. The Department of Justice made its first FGM-specific grants, including over $1 million to a technical-assistance provider partnered with the U.S. End FGM/C Network.

Six years after Dorkenoo told intactivists that leaving boys out was strategic, she was running the largest government-funded FGM campaign in history.

From one perspective, the strategy worked. The anti-FGM movement achieved money and power by ignoring the suffering of men and male children.

However, if we follow the money, there is another narrative: pro-circumcision medical and government organizations bought the anti-FGM movement.

Pro-Circumcision Groups Bought The Anti-FGM Movement

The funders of anti-FGM organizations are pro-circumcision.

• Government: The same U.S. government that funds these organizations through Department of Justice grants has supported 35.1 million circumcisions through PEPFAR since WHO and UNAIDS recommended male circumcision in 2007, putting nearly $2 billion into it over the next decade. Medicaid covers routine newborn circumcision in 33 states. The State Department ran a coordinated campaign against circumcision bans in European countries. Congress wrote prohibitions on male circumcision bans into the Wolf Act as religious-freedom violations the State Department must monitor.

• Bill & Melinda Gates Foundation gave Equality Now $8,297,470 across multiple grants, including a $1 million grant in September 2024. The same foundation has committed approximately $252 million across 44 grants to male circumcision programs. Those grants funded Population Services International to circumcise nearly 650,000 men in two countries, the Johns Hopkins randomized trial in Uganda, Weill Cornell Medical College to test a circumcision device on infants, and the University of Manitoba to introduce early-infant circumcision in Kenya.

• Human Dignity Foundation financed the creation of the End FGM European Network through an approximately €2.2 million grant to Amnesty International. HDF was founded by Dr. John Climax, co-founder of ICON, a major clinical-research company.

• Morris and Alma Schapiro Fund gave $250,000 to Safe Hands for Girls and separately funds Memorial Sloan Kettering Cancer Center ($550,000) and the Prostate Cancer Foundation ($400,000).

• Oak Foundation funds the broader anti-FGM movement’s infrastructure through the Five Foundation and separately funded a Botswana HIV trial that included expanded access to circumcision services.

• Novo Nordisk Foundation gave $650,000 to the UNFPA-UNICEF Joint Programme on FGM. Novo Nordisk Foundation is an enterprise foundation centered on medical science and biotechnology.

• Children’s Investment Fund Foundation participates in the HER Africa Funder Alliance, a funder collaborative created by the Five Foundation to finance African anti-FGM organizations. CIFF’s portfolio includes global health programs across the same institutional networks.

I have documented these conflicts organization by organization in these articles:

• Do Anti-FGM Organizations Have a Financial Conflict of Interest?

• Is the Anti-FGM Movement a Government Sock-Puppet?

While the strategic decision to take money from pro-circumcision groups might have increased the wealth of the anti-FGM movement, what did this cost them?

What The Strategy Cost

Taking pro-circumcision money from government and medical interests made it so anti-FGM organizations cannot oppose female genital cutting when doing so means opposing the state and those financial interests and must support male genital cutting when the state and their financial interests demand it.

Two ways that is currently manifesting:

• Anti-FGM organizations will not say FGM doctors should lose their licenses. Dr. Jumana Nagarwala and Dr. Fakhruddin Attar, the physicians charged in America’s first federal FGM prosecution, hold active medical licenses in Michigan today. On July 25, I emailed Equality Now, the U.S. End FGM/C Network, and Sahiyo asking whether physicians who perform FGM on children should hold medical licenses. None of them answered. A medical licensing board is a government agency. Criticizing its decision means criticizing the government while depending on the government for operating revenue.

• Those same anti-FGM organizations will go to court to keep boys out of a genital cutting law. On July 23, two days before ignoring those emails, the same three organizations asked an Oregon court to reject a lawsuit brought by three men challenging the state’s FGM statutes as sex discrimination. Their brief argues that including male circumcision would “needlessly and negatively impact” the work to end FGM. Extending the law takes nothing from girls. But it would challenge the medical system their donors finance.

Read about these two issues here:

• Are Anti-FGM Organizations Fine With Licensing FGM Doctors?

• Anti-FGM Groups Protect Male Circumcision While Ignoring FGM Licensing

Dorkenoo's strategy was presented as a sort of triage: Protect girls first, because that fight can be won. Come back and save the boys later.

However, that strategy is only defensible if:

1. Girls are actually protected.

2. The movement eventually returns to the issue of male genital cutting with their newfound resources and support.

Instead, the strategy sacrificed both their core mission of ending female genital cutting and the issue of male genital cutting.

Anti-FGM organizations are now ignoring the licensing medical doctors who performed female genital cutting while filing legal briefs against male circumcision lawsuits. As a strategy to end female genital cutting, it failed. As a strategy to make money, it succeeded.

In other words, the movement sold out.

The Pro-Circumcision Strategy

Consider this from the perspective of pro-circumcision organizations. There is a growing movement against all genital cutting. What is your best strategy to stop them?

You could fight the genital autonomy movement directly, but that draws attention to them and the comparison between male and female genital cutting. A better strategy would be to divide them and fund a controlled opposition movement — one that appears to be against “genital cutting” but never actually threatens your money, power, and institutional connections.

Whether or not it was a conscious strategy, this is what pro-circumcision organizations did to the tune of millions of dollars. They funded organizations that opposed female genital cutting with a narrative that excluded male genital cutting, and gave them access to law firms, government contracts, UN partnerships, and media attention.

From this perspective, the $8.3 million the Gates Foundation gave Equality Now is not a grant to end FGM. It is the cost of ensuring that the world’s most prominent anti-genital-cutting organizations will never threaten the $252 million circumcision portfolio. The DOJ grants to Sahiyo are not the cost of ending FGM in the Dawoodi Bohra community. They are the cost of making sure the organization founded by that community’s survivors will not say that a doctor who cut their girls should lose her license.

What pro-circumcision organizations are buying is a credible voice against genital cutting that draws the line exactly where they need it drawn to protect their interests. Now anyone who argues that cutting a boy is the same as cutting a girl is not arguing against pro-circumcision organizations, but anti-FGM organizations. The movement that should be their biggest threat is on their payroll and doing their work for them.

How Anti-FGM Narrative Supports Male Genital Cutting

Anti-FGM organizations have framed the issue of genital cutting as exclusively as violence against women and girls, creating a narrative that prevents acknowledging the ways male children are harmed and makes cooperation with genital autonomy organizations impossible:

• The joint amicus brief filed by Equality Now, Sahiyo, Safe Hands for Girls, and WeSpeakOut in the Nagarwala case presents FGM as a violation of girls’ and women’s rights, not children’s rights. The framework itself excludes boys.

• AHA Foundation’s terminology article argues the comparison with male circumcision is used to diminish FGM’s seriousness. An AHA-hosted advocate profile describes raising male circumcision in FGM-law discussions as “a distraction.”

• Equality Now’s coverage of the 2026 Indian Supreme Court hearing presents the comparison with male circumcision as an argument made by defenders of the practice. Comparing FGM to circumcision is cast as defending FGM, not as defending children.

• The World Health Organization said in 1996 that FGM could not be likened to male circumcision. UNFPA says the term “mutilation” helps establish a clear distinction from male circumcision. The U.S. Office on Women’s Health states directly that FGM is not the same as male circumcision. These institutional positions provide the authoritative language anti-FGM organizations invoke when resisting a universal genital-autonomy frame.

• Political scientist Charli Carpenter analyzed how advocacy networks treat male circumcision as a “lost cause.” She found that linking the issue to FGM triggered gatekeeping concerns: competition for attention, confusion of the anti-FGM message, conflict with the women’s-rights framing, and fear of weakening a successful campaign.

• When GAMS Belgium organized a 2019 expert meeting examining FGM in relation to male genital cutting, the invitation generated negative reactions from partners within the anti-FGM network itself. Some feared that opening the comparison meant weakening opposition to FGM.

• In July 2026, Equality Now, the U.S. End FGM/C Network, and Sahiyo went to court in Oregon to oppose a lawsuit challenging the state's FGM statutes as sex discrimination. Their brief claims that FGM is rooted in gender-based violence and the control of women’s sexuality, has no medical benefits, and causes severe lifelong harm, while male circumcision does not.

The pro-circumcision strategy worked. There is now a large movement against “genital cutting” that ignored the most prolific form of genital cutting and excludes real opposition to their interests.

Are Anti-FGM Organizations Controlled Opposition?

Political scientists have a term for what happens when funders redirect a social movement’s agenda: movement capture. Megan Ming Francis coined it to describe how the Garland Fund used its money to shift the NAACP from fighting lynching to fighting school segregation. The funder didn’t oppose the NAACP. It supported it, on the condition that it pursue the funder’s priority rather than its own.

A 2025 paper on controlled opposition in democracies takes this further. It argues that in liberal democracies, controlled opposition no longer requires spies or informants. It runs on NGO funding dependencies and what the author calls “performative dissent”: organizations that look like opposition, hold the credentials of opposition, and never threaten the interests of the people paying them.

The anti-FGM movement fits this definition. Its organizations receive funding from governments and foundations that support male circumcision. They have adopted a narrative that treats any comparison between male and female genital cutting as an attack on their mission. They show up in court to defend FGM laws from being extended to boys but will not answer an email about whether FGM doctors should keep their licenses. They produce laws, conferences, reports, and amicus briefs. They do not produce prosecutions, license revocations, or any outcome that would require confronting the government agencies and medical institutions that fund them.

Whether this is controlled opposition depends on how you define the term. If it requires a conscious conspiracy, some secret meeting in a room where a nefarious cabal decided to buy a movement, I’m not sure there is one. Each groups appears to be acting on their interests. Pro-circumcision medical and government groups want to fund organizations that won’t oppose circumcision. Anti-FGM groups want mainstream support and funding. Everyone wins — except for the children. This appears to be the result of systems, not conspiracy. However, the result is the same as if there was conspiracy.

The anti-FGM movement occupies the space where a real genital autonomy movement should stand. It holds media contacts, UN partnerships, and legal budgets, but uses those to oppose efforts against genital cutting and ignore the licensing of FGM doctors. Whether or not anyone consciously asked them to this, this is exactly what anti-FGM organizations would do if they were controlled opposition.

For years, intactivists have wondered why anti-FGM groups will not work with them. The answer is that they were built to never do that.

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Three anti-FGM groups went to court in Oregon to oppose a circumcision lawsuit, but none of them will answer an email about the ongoing medical licensing of FGM doctors.

Hadachek, Hellewell & Moody v. State of Oregon, No. 25CV18224, is a lawsuit against the state in Multnomah County Circuit Court that argues Oregon’s anti-FGM statutes are sex discrimination because the statutes prohibit female genital cutting while not also prohibiting male genital cutting and routine infant circumcision. The three plaintiffs are represented by Eric Clopper of the Clopper Law Firm and Lake Perriguey of Law Works, with backing from Intact Global.

On July 23, Equality Now, the U.S. End FGM/C Network, and Sahiyo filed a joint amicus brief taking the state’s side against Clopper’s clients. The brief argues that FGM and male circumcision are medically and legally distinct, because FGM is rooted in gender-based violence and the control of women’s sexuality, has no medical benefits, and causes severe lifelong harm, while male circumcision does not, and that the legislature can address one harm without addressing all harms. The authors claim they “do not take a position for or against the regulation of male circumcision,” but asked the court to reject remedies the plaintiffs seek, including extending the statutes to boys.

On July 25, two days after the anti-FGM organizations’ motion to oppose a circumcision lawsuit, I emailed the same three organizations asking whether each was aware that Dr. Jumana Nagarwala and Dr. Fakhruddin Attar, the physicians charged in America’s first federal FGM prosecution, hold active medical licenses, whether their organizations intended to take action, and whether physicians who perform FGM on children should hold medical licenses. None of the three responded.

The brief opposing a lawsuit around male circumcision cites the Nagarwala case twice. Equality Now lists it among the cases where it has filed amicus briefs. Sahiyo describes itself in the filing as founded by survivors and advocates connected to the Dawoodi Bohra community, the community at the center of the Nagarwala prosecution. Both organizations filed in the federal case in 2018.

Now, those organizations are using international law firms to oppose a lawsuit around male circumcision, while silent on whether doctors charged in the first federal FGM case should still practice medicine.

The brief filed by anti-FGM organizations cites the 2015 English family court ruling In re B and G (Children) (No. 2). It quotes the judge saying FGM Types I, II, and III are “very much more invasive than male circumcision” and that there is “a very clear distinction in family law” between the two. Both quotations are cut mid-sentence. The first goes on to say that some forms of Type IV FGM are much less invasive than male circumcision. The second opens with “although both involve significant harm.” The same judge held that if Type IV FGM is significant harm, male circumcision must be too, and that the law treats them differently not because of medical evidence but because society still tolerates one and no longer tolerates the other. The ruling supports the plaintiffs’ argument, but the brief omits those aspects.

The behavior of anti-FGM organizations here is consistent with a government sock-puppet. They support the state in defending male circumcision, while ignoring an issue that would require criticizing state action, despite it being central to their primary mission and previous action.

These anti-FGM organizations take government money. Sahiyo reported 60.3% of its operating budget as government grants. The U.S. End FGM/C Network is a Department of Justice technical-assistance provider that does not disclose its budget. Equality Now reported $500,054 in government grants in 2021.

Many also have ties to the medical system and non-profit funding that supports male circumcision. Equality Now received $8.3 million from the Gates Foundation, one of the primary funders of African circumcision campaigns.

The court heard argument on the state’s summary judgment motion on September 14 and did not rule from the bench. None of the anti-FGM organizations mentioned have responded to questions about the continued medical licensing of FGM doctors.

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Anti-FGM organizations receive money from the government. They also receive private funding from foundations with ties to the medical system. The licensing of two FGM doctors sits at the intersection of both funding streams. Pursuing it means criticizing both a government medical board and the professional infrastructure their own donors finance. This is a financial conflict of interest.

Context

Dr. Jumana Nagarwala and Dr. Fakhruddin Attar were charged in the first federal FGM prosecution in U.S. history. Both hold active, unrestricted Michigan medical licenses. Michigan’s Bureau of Professional Licensing closed investigations into both licenses before the federal prosecution ended. Memos explaining why their cases were closed have been withheld from the public.

I asked eight anti-FGM organizations whether the physicians should continue to hold active medical licenses. Six did not respond. One responded without answering the questions. One had to be told to read the reporting before it revised its position.

Full story on anti-FGM organizations response:

The Government Conflict

As I reported in “Is the Anti-FGM Movement a Government Sock-Puppet?,” anti-FGM organizations receive government money.

Government funding creates one conflict of interest: pursuing the licensing issue means criticizing a state government agency, and these organizations depend on government agencies for grants and contracts.

You can read that full article here:

However, government funding is only half the problem. The rest of the funding of anti-FGM organizations has ties to the medical system.

The Medical Conflict

I researched the fourteen largest private foundations funding the anti-FGM movement. Seven have ties to medicine, hospitals, biomedical research, pharmaceuticals, or public health as a central program area, a material grant category, or the source of the founding fortune.

Three are biomedical or global-health funders:

• Bill & Melinda Gates Foundation gave Equality Now $8,297,470 across multiple grants, including a $1 million grant in September 2024. Gates is one of the world’s largest global-health and vaccination funders. It committed $1.9 billion to Global Health in 2024 and pledged $1.6 billion to Gavi in 2020 alone. It works through WHO, UNICEF, universities, pharmaceutical firms, and national public-health systems.

• Children’s Investment Fund Foundation participates in the HER Africa Funder Alliance, a funder collaborative created by the Five Foundation to finance African anti-FGM organizations. CIFF’s health and nutrition portfolio includes HIV medication, reproductive health, maternal health, government health systems, and pharmaceutical-access programs.

• Novo Nordisk Foundation gave $650,000 to the UNFPA-UNICEF Joint Programme on FGM. It is an enterprise foundation centered on medical science, biotechnology, and life-science research, and committed DKK 1.8 billion to its vaccine and immunity initiative.

Three make medical grants:

• Oak Foundation gave $466,667 over three years to the Five Foundation, a coordinating body for anti-FGM funders. Its Special Interest Programme expressly includes medical research and healthcare projects.

• Conrad N. Hilton Foundation participates in the HER Africa Funder Alliance. Its longstanding programs include multiple sclerosis, avoidable blindness, substance-use prevention, and children affected by HIV/AIDS.

• Morris and Alma Schapiro Fund gave $250,000 to Safe Hands for Girls and separately funds Memorial Sloan Kettering Cancer Center ($550,000) and the Prostate Cancer Foundation ($400,000).

One was built on a medical-industry fortune:

• Human Dignity Foundation financed the creation of the End FGM European Network through an approximately €2.2 million grant to Amnesty International. HDF was founded by Dr. John Climax, co-founder of ICON, a major clinical-research company that runs trials for pharmaceutical firms. Climax remains founder and chair, and the foundation’s board and staff draw partly from the pharmaceutical sector.

The largest private donors to anti-FGM organizations are embedded in the medical system. How has the medical system responded to licensing FGM doctors?

Medical Complicity

The medical system has not condemned licensing FGM doctors.

As I previously reported, the Federation of State Medical Boards did not say that physicians charged in a federal FGM prosecution should lose their medical licenses. The American Medical Association would not condemn licensing FGM doctors, and deferred to the Federation of State Medical Boards. No insurer would say that FGM doctors should be removed from their network.

No medical organization would say that FGM doctors should lose their licenses, including the American College of Physicians, American Academy of Pediatrics, American College of Obstetricians and Gynecologists, and American College of Emergency Physicians.

The anti-FGM organizations’ private donors are embedded in this medical infrastructure. Pushing a medical board to revoke a physician’s license means pushing against the professional system their funders finance and participate in. Anti-FGM organizations’ response mirrors the response of medical organizations.

Intersectional Conflict

The licensing issue sits at the intersection of both medical and government conflicts. Pursuing it would require anti-FGM organizations to act against the interests of both.

Every organization has at least one conflict:

• Equality Now reported $500,054 in government grants in 2021 and received $8,297,470 from the Gates Foundation, one of the world’s largest global-health funders. Both conflicts.

• End FGM European Network receives approximately 96% of its revenue from the European Commission and was created with an approximately €2.2 million grant from Human Dignity Foundation, whose founder co-founded ICON, a clinical-research company. Both conflicts.

• Sahiyo reported 60.3% of its operating budget as government grants, including DOJ and HHS funding. Government conflict.

• Tahirih Justice Center reported $5,552,673 in government grants in 2024, approximately 46.6% of revenue. Government conflict.

• AHA Foundation reported $38,000 in government grants in 2024 and holds a $500,000 DOJ award. More than $2 million of its identified private funding came through donor-advised funds that do not disclose the underlying donors. Government conflict; private donors untraceable.

• U.S. End FGM/C Network is a DOJ Office for Victims of Crime technical-assistance provider and participates in a $300,000 DOJ cooperative agreement. It is fiscally sponsored by Reading Room Cleveland and does not disclose its budget or donors. Government conflict; private donors undisclosed.

• Orchid Project is a funded participant in a UK FCDO program on ending FGM; its share is not disclosed. Government conflict.

• Safe Hands for Girls has no verified government funding. Its largest identified donor, the Schapiro Fund, gave $250,000 and separately funds Memorial Sloan Kettering and the Prostate Cancer Foundation. Medical conflict.

The licensing of FGM doctors requires opposing both at once. None did.

The Conflict

Anti-FGM organizations have a financial conflict of interest when it comes to opposing the licensing of FGM doctors.

The organizations with the budgets, the legal teams, the policy staff, and the stated mission to end female genital mutilation have not pursued the licensing of two physicians charged in the first federal FGM prosecution.

The licensing issue requires them to challenge a government medical board. Their government funders pay them to serve government agencies, not to criticize them. Their private donors are embedded in the medical system they would need to challenge.

While these organizations might care about FGM, does their funding allow them to act on it, when acting means challenging the institutions that fund them?

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Anti-FGM organizations receive government funding. They act when activism means supporting government prosecution. They are silent when it means criticizing the government. Is the anti-FGM movement a government sock-puppet?

Context

Dr. Jumana Nagarwala and Dr. Fakhruddin Attar were charged in the first federal FGM prosecution in U.S. history. The district court dismissed the FGM counts and held the federal statute unconstitutional in November 2018. Despite the FGM being undisputed, neither physician was convicted.

My original reporting revealed that Michigan's Bureau of Professional Licensing closed investigations into both licenses before the federal prosecution ended. Despite their involvement in FGM, both hold active Michigan medical licenses with no disciplinary action on their public records. Michigan's Bureau of Professional Licensing lied to the press about its investigation, dismissed physician complaints, and renewed Nagarwala's medical license during my investigation. It has refused to tell the public why the doctors are still licensed. Memos explaining why their case was closed have been withheld from the public.

How did anti-FGM organizations respond to the continued licensing of FGM doctors?

They did nothing.

Anti-FGM Intaction

As I previously reported:

I asked eight organizations that work to end female genital mutilation whether two physicians charged in America’s first federal FGM prosecution should continue to hold active medical licenses. Six did not respond. One responded, but did not answer the questions. One initially took a position that meant that FGM doctors should keep their licenses, and had to be told to read the reporting they were responding to before they gave a new comment.

None showed they were aware the FGM doctors were still licensed. Why?

Case Involvement

Anti-FGM organizations were actively involved in the Nagarwala case:

• AHA Foundation claims it connected the original whistleblower to federal law enforcement. It filed its own amicus brief through White & Case on September 24, 2018. Amanda Parker testified before the Michigan House Committee on Law and Justice in May 2017 and helped develop Michigan’s state FGM legislation. AHA says it worked with members of both parties on the revised federal ban signed in January 2021.

• Equality Now was the lead organization on a joint amicus brief filed September 24, 2018 with Sahiyo, Safe Hands for Girls, and WeSpeakOut. Shelby Quast gave media commentary after Nagarwala’s arrest and wrote two case-centered essays for Ms. magazine.

• Sahiyo was a named party on the joint amicus brief. Sahiyo organized a roundtable with the Michigan Department of Health and Human Services on October 9, 2017 and later produced a podcast episode on the prosecution’s effect on Bohra survivors.

• Safe Hands for Girls was a named party on the joint amicus brief. Founder Jaha Dukureh gave media commentary throughout the prosecution.

• U.S. End FGM/C Network claims it joined the amicus brief, but the filed document does not list the Network in its caption or signature block. The Network sent a letter to Speaker Pelosi on September 10, 2020 urging passage of the STOP FGM Act and issued a statement after the final dismissal in 2021.

• Tahirih Justice Center participated in an October 2017 Michigan DHHS roundtable on the case with Sahiyo and Equality Now.

• Orchid Project published a response to the constitutional ruling on November 21, 2018.

• End FGM European Network issued a press release the day after the ruling.

Given that these organizations were aware of the case, why were they not tracking the medical licensing? Did they just lack the resources?

No. The anti-FGM movement is a multimillion dollar operation.

Significant Resources

Anti-FGM organizations have significant resources:

• Equality Now reported $12,083,779 in revenue and $27,682,465 in net assets in its 2024 Form 990. It also operates a U.K. entity that reported £2.91 million in income.

• Tahirih Justice Center reported $11,920,808 in revenue in its 2024 Form 990 and $10,151,038 in net assets. Its 2025 audit shows an additional $29,241,898 in donated professional services.

• AHA Foundation reported $1,187,403 in revenue in 2024. It spent $593,000 on FGM legislative advocacy and support, roughly 45.5% of all expenses.

• Orchid Project reported £957,920 in income for the year ending March 2025.

• Safe Hands for Girls reported $877,303 in revenue in 2024.

• End FGM European Network reported €684,048 in revenue in 2024.

• Sahiyo reported a $576,444 operating budget for 2023-24.

• U.S. End FGM/C Network does not file its own Form 990. It operates through fiscal sponsorship by Reading Room Cleveland, Inc. and does not publicly disclose its budget.

Lack of awareness or involvement in the medical licensing case can’t be explained by lack of resources. These organizations had the budget.

But where does that money come from?

The government.

Government Funding

Most anti-FGM organizations are government funded.

• End FGM European Network receives approximately 96% of its revenue from the European Commission or EU-cofunded projects, roughly €656,686 in 2024.

• Sahiyo reported 60.3% of its operating budget as government grants, approximately $347,596. Its government funders include the DOJ Office on Violence Against Women, HHS Administration for Children and Families, and Washington State Department of Health.

• Tahirih Justice Center reported $5,552,673 in government grants in its 2024 Form 990, approximately 46.6% of revenue. Its 2025 federal expenditure schedule lists $2,638,741 from the Departments of Justice, HHS, Labor, and Treasury.

• AHA Foundation reported $38,000 in government grants in 2024, approximately 3.2% of revenue. It also holds a separate $500,000 DOJ Office on Violence Against Women award for a 36-month FGM prevention project.

• Orchid Project is a funded participant in a U.K. Foreign, Commonwealth and Development Office program on ending FGM. Its individual share is not publicly disclosed.

• U.S. End FGM/C Network is a DOJ Office for Victims of Crime technical-assistance provider and participates in a $300,000 DOJ cooperative agreement and a Washington State contract. Its individual shares and total budget are not disclosed.

• Equality Now reported $500,000 in government grants in 2021 and appears in EU grant records.

What do these organizations do with all that money they get from the government?

They send it back to the government in the form of lobbying and services.

Government Lobbying and Services

The primary activism of many anti-FGM organizations is lobbying the government and fulfilling government contracts.

• AHA Foundation spent $593,000 on “FGM legislative advocacy and support” in 2024, approximately 45.5% of all expenses that year. Its Form 990 states AHA worked closely with legislators in Washington, D.C.

• Tahirih Justice Center reported $33,129 in statutory lobbying in 2024, up from $14,870 in 2021. Its broader advocacy spending was $1,873,463 in 2024. Tahirih’s auditors state the organization holds cost-reimbursable grants and contracts with U.S. government and state agencies.

• Equality Now reported $67,602 in statutory lobbying in 2023 and $0 in 2024. Its program descriptions include training law-enforcement officials, prosecutors, and judges. Through the SOAWR coalition, Equality Now trains government officials and submitted 78 legal submissions to governmental bodies in 2024.

• End FGM European Network declared “no lobbying costs” on its EU transparency register while spending approximately €394,524 on “core activities” that include advocacy, communications, and governance. In 2024, the Network secured signatures from 144 European election candidates, 20 of whom became MEPs, and sent policy requests to incoming Commissioners.

• Sahiyo holds government contracts to implement Washington State’s FGM law and participates in a $300,000 DOJ cooperative agreement to provide training and technical assistance. Its program spending includes work with government officials to build systems of care.

• U.S. End FGM/C Network is a DOJ Office for Victims of Crime technical-assistance provider, participates in the same $300,000 DOJ cooperative agreement as Sahiyo, and holds a Washington State Department of Health contract with Sahiyo and Mother Africa. The Network describes its work as advocating for state FGM laws, strengthening the federal FGM law, and seeking increased government funding.

• Safe Hands for Girls trained Gambian prosecutors and Child Welfare Officers on investigating and prosecuting FGM. Its Form 990 describes sponsoring lawmakers’ visits to Egypt and engagement with governments and UN bodies to shape policy.

• Orchid Project holds responsibility for global advocacy within a U.K. FCDO-funded consortium and submits evidence to U.K. parliamentary inquiries on government policy toward FGM.

If we follow the money, these are not independent “grassroots” organizations. They receive money from the government, and in turn, serve the government and lobby for its preferred policies.

There is a name for this arrangement: sock puppets.

Sock Puppets

The 2012 paper Sock Puppets: How the Government Lobbies Itself and Why by Christopher Snowdon at the Institute of Economic Affairs defines sock-puppet organizations as state-funded pressure groups that “masquerade as civil society while promoting the ideology of the political elite.”

These organizations create “the illusion of grassroots support for new legislation” by appearing to be independent, instead of “government lobbying government.” If these organizations were funded by an industry, “we would call them front groups.”

The anti-FGM movement in the United States fits this model. Government money flows to these organizations, which they then use to lobby for the laws that support government prosecutions, to train the government officials to enforce those laws, and to seek more government funding. The money flows in a circle.

Snowdon is careful to note that this does not mean activists involved in sock-puppet organizations are not sincere or that their cause does not have merit. However, sock-puppet organizations create several issues, one of which is that those organizations lose any independent voice they once had, and “speak loudly when it agrees with its funders, but fall silent when it does not.”

Anti-FGM organizations’ actions align to government incentives:

• Anti-FGM organizations were loud when it meant supporting the government. Eight organizations filed amicus briefs, testified before state legislatures, gave media commentary, organized government roundtables, and lobbied Congress. All aligned with the Department of Justice's prosecution.

• Anti-FGM organizations went silent when it meant criticizing the government. When I asked all eight whether FGM doctors should continue to hold active medical licenses, six did not respond, one responded without answering the questions, and one had to be told to read the reporting before it revised its position. None knew the doctors were still licensed.

Even though there is no direct link between government funding and anti-FGM organization inaction, Snowdon’s model doesn’t require one. Incentives alone are enough to explain their behavior.

Supporting a federal prosecution aligned with the government. Criticizing a state licensing board's decision did not. So they did one, but not the other.

Grassroots Activism

One of the costs of sock-puppets is that they crowd out genuine independent voices by forcing them to compete against millions in public money with only their own resources.

The anti-FGM movement has tens of millions of dollars in annual revenue. The organizations in this article receive government grants, hold government contracts, and spend money lobbying the government. They did nothing to investigate the medical licensing of FGM doctors.

I am an independent journalist spending my own money. I did all of the research in this investigation in my spare time. I do not have government grants. I have a GoFundMe. I broke the story that they were still licensed. This is what actual grassroots look like. This is what a genuine anti-FGM movement would support.

When I reached out to the eight anti-FGM organizations mentioned, they did not pursue action that would put them in conflict with a government agency, instead of profiting from one. Their response is consistent with the behavior of sock-puppet organizations.

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I asked eight organizations that work to end female genital mutilation whether two physicians charged in America’s first federal FGM prosecution should continue to hold active medical licenses. Six did not respond. One responded, but did not answer the questions. One initially took a position that meant that FGM doctors should keep their licenses, and had to be told to read the reporting they were responding to before they gave a new comment.

As previously reported, Dr. Jumana Nagarwala (License No. 4301071795) and Dr. Fakhruddin Attar (License No. 4301067384) hold active, unrestricted Michigan medical licenses. The state investigations into their licenses were closed before the federal court ruling. Neither physician was convicted.

On July 25, I emailed Equality Now, the U.S. End FGM/C Network, Sahiyo, the AHA Foundation, the Tahirih Justice Center, Safe Hands for Girls, the Orchid Project, and the End FGM European Network, asking each organization three questions:

1. Is your organization aware of this case and its current status?

2. Does your organization intend to take any action or make any public statement?

3. Does your organization believe physicians who perform female genital mutilation on children should hold active medical licenses?

I requested response by Friday, July 31.

Equality Now did not respond. Safe Hands for Girls did not respond. The Orchid Project did not respond. The End FGM European Network did not respond.

Sahiyo was founded by members of the Dawoodi Bohra community, the specific community at the center of the Nagarwala case. Its website describes FGM within the Bohra community as its primary focus area. Sahiyo did not respond.

The AAP’s clinical report on FGM in children directs clinicians to the U.S. End FGM/C Network’s website to find a regional FGM expert. The U.S. End FGM/C Network did not respond.

I followed up by emailing its executive director, Caitlin LeMay, directly on August 4. I noted the original request had received no response and that a colleague at another organization had referred me to LeMay by name. The deadline was Friday, August 7. She did not respond.

Two organizations did respond: the AHA Foundation and the Tahirih Justice Center.

The AHA Foundation was founded by Ayaan Hirsi Ali, herself a survivor of FGM. On July 31, the deadline for my questions, Michele Hanash, the Director of Policy and Women’s Programs at the AHA Foundation, responded with the following:

1- The Nagarwala case? Yes.

2 - We filed an Amicus Brief in the Nagarwala case and have spoken about it. Is there an update in particular that you are referring to?

3- We support and promote that any physician found guilty of FGM should be subject to automatic revocation of their medical license.

AHA’s position, as stated in this email, “that any physician found guilty of FGM should be subject to automatic revocation of their medical license” [emphasis added] implies that the organization would support the continued licensing of the FGM doctors, since neither Nagarwala nor Attar were found guilty.

However, their reply indicates that they did not read my email or reporting before making a public statement. I did not ask them about the legal case, but the medical licensing. Before the questions, my email read:

I am writing to request comment on two FGM doctors who still have a medical license.

Both physicians charged in United States v. Nagarwala, America’s first federal FGM prosecution, hold active, unrestricted medical licenses in Michigan today. Investigations into their license were closed before the federal court ruling.

My reporting on this story is here: https://www.hegemonmedia.com/p/fgm-doctors-still-licensed

Both my email and reporting told them what I was asking about. Though AHA replies to their email (unlike most anti-FGM organizations contacted), their reply indicated they did not read it. Had I not followed up, it would have been reasonable to run the headline “Anti-FGM Organization Supports Licensing FGM Doctors” with their comment.

Instead, I replied, laying out the facts and suggested they read the reporting before responding further. I noted that Nagarwala’s licensing investigation was formally closed September 25, 2018, one day after AHA filed its Amicus Brief.

Michele Hanash of AHA replied that:

We were unaware that Nagarwala’s medical license had recently been renewed. Thank you for bringing this to our attention.We have been exploring potential avenues for action, including possible civil remedies for survivors, although those options did not appear to be feasible. However, we are now looking into what additional actions may be available in connection with this case.

We believe the facts of the case were sufficient to warrant revocation of the physicians’ medical licenses, and we do not understand why the licensing board would have simply closed the matter without taking further action.

I sent a third email offering to meet with them and share what I’ve learned about the medical licensing case after six months of investigation and filing over 100 public records requests. They did not reply.

The Tahirih Justice Center responded on July 27. Casey Carter Swegman, Director of Public Policy, did not answer any of the three questions. She referred me to Nicole Warren at Johns Hopkins University, an external expert not affiliated with Tahirih.

I replied the same day, thanked Swegman for the referral, noted I was documenting each organization’s own position, and restated the three questions. Tahirih did not answer.

An hour later, Rachel Pulda, Tahirih’s Director of Communications, sent a second referral, directing me to Caitlin LeMay at the U.S. End FGM/C Network, an organization I had already contacted on July 25. Tahirih sent two emails and answered zero questions. The organization knew who to refer me to. It would not say what it thought.

Warren, the referred expert, responded substantively within thirty minutes. Nicole Warren is an Associate Professor at Johns Hopkins University School of Nursing and Women’s Health Director at the HEAL Refugee Health and Asylum Cooperative. She answered all three questions directly.

On the licensing status, Warren wrote:

“Allowing these individuals to be licensed suggests that FGM/C is not ‘worth’ being held accountable. This is contradictory to every legal and health profession guidance at local, state, national, and international levels. I have heard dozens of first-hand accounts of FGM/C - there is no benefit to the individual, only long-term, mostly irreversible, psychological and physical harm. I do not believe any clinician, even those from a community that practices FGM/C, who understand these impacts would continue the practice.”

On the role of licensing boards, she wrote:

“I am not a physician but I feel strongly that any entity that licenses health care providers has an obligation to hold applicants accountable for unethical behavior including FGM/C.”

Warren’s initial response contained two factual errors: she identified the physician as a family physician and cited the AAFP’s policy, which does not apply to Nagarwala’s specialty. I sent corrections the same day with the accurate details. Warren acknowledged them and said she would reply in the next couple of days with a revised response. Her answer on what continued licensing signals does not depend on either error and stands as written. She did not send the revised response.

Warren referred me to Janine Young, lead author of the AAP’s clinical standard on FGM in children. Young answered all three questions in writing and stated that anyone who performs “any medically unnecessary treatments on a child” should be thoroughly investigated by the medical board and that the state should follow a structured disciplinary process. You can read her full statement in previous reporting here.

Of the eight organizations contacted, only one stated that the facts warrant revocation of the physicians’ medical licenses. That organization did not know the licenses were still active until I told them twice, and initially gave a response that implied they were fine with the FGM doctors’ continued licensing. They did not respond when I offered to share what I have learned through six months of investigation.

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One final note:

• Equality Now: $12,083,779 in revenue for fiscal year 2024, $28.4 million in total assets.

• Safe Hands for Girls: $877,303 in revenue.

• Orchid Project: £957,920 in income.

• End FGM European Network: €684,048 in revenue, with 66% from a European Commission operating grant and 30% from EU-cofunded projects.

• Sahiyo: $576,444 operating budget.

• U.S. End FGM/C Network: does not publish standalone financial statements; operates under a fiscal sponsor and does not publicly disclose its annual budget.

• AHA Foundation: $1,187,403 in revenue.

• Tahirih Justice Center: $11.9 million in Form 990 revenue; including donated professional services, its stated total budget reaches $36.7 million.

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Does America have a mandatory reporting crisis for female genital cutting?

Before I discovered that two physicians federally prosecuted for FGM still hold active, unrestricted Michigan medical licenses, I was researching mandatory reporting around female genital cutting.

Given that certain populations have majority female genital cutting rate and those populations are growing in the United States, then it follows that there should also be high mandatory reporting rates from doctors who see those populations.

I assumed that the first federal prosecution of FGM in the United States would have some information on this and went to look up how the medical license was taken in that case… only to discover it wasn’t. That lead to the six month investigation you can read in detail here:

However, the original mandatory reporting question remains unanswered.

Summary

Based on the available numbers, here is what the math shows:

• 390,000 women/girls in the U.S. estimated living with FGM

• 31,000 girls under 18 at risk.

• 39,000 OB/GYNs have likely seen it clinically.

• 30,000 doctors in a position to have filed a mandatory report on a minor.

• Failure to report suspected child abuse is a crime in 46 states, typically a misdemeanor punishable by up to a year in jail and fines up to $5,000.

• There are essentially zero at the national level.

That means approximately 30,000 doctors might have failed to fulfill a legal obligation to report suspected abuse of a minor, which carries criminal penalties in nearly every state.

How I arrived at those numbers:

Here is the math behind that.

Skip if you’re just here for the commentary, but read in detail if you want to check my numbers.

Survivors

The 2023 AHA Foundation/Orchid Project analysis, Female Genital Mutilation/Cutting in the United States, identified 1,325,989 U.S. women and girls with ancestry or birthplace links to countries or communities where FGM is practiced. Using American Community Survey data, country-of-origin prevalence rates, age-at-cutting data, and migration and acculturation adjustments, the study estimated that 384,714 of them are living with FGM. A separate estimate of approximately 5,500 Dawoodi Bohra women and girls, calculated from congregation and community size rather than the ACS method, brings the central estimate to about 390,000.

That is roughly 0.23% of all women and girls in the United States.

384,714 + 5,500 = 390,214
390,214 ÷ 172,601,353 U.S. women/girls = 0.23%

Minors at risk

The same study estimated 30,956 girls under 18 are still at risk of FGM. These are the cases most directly relevant to mandatory reporting — a minor who has undergone FGM, is suspected to have undergone it, or faces credible risk.

30,956 ÷ 73,483,744 U.S. minors = 0.04% of all minors
30,956 ÷ 35,800,000 U.S. girls under 18 = 0.09% of girls under 18

This figure likely undercounts. Girls cut in infancy — common in some Nigerian and Indonesian communities — are modeled as already living with FGM rather than “at risk,” so they don’t appear in the 30,956.

Doctors who have seen it

A national survey of OB/GYN physicians published in 2021 found that 66% of clinically active respondents had cared for a patient who had undergone female genital cutting. The AAMC counts 58,739 professionally active OB/GYNs in the United States.

58,739 × 0.66 = 38,768

Roughly 39,000 OB/GYNs have likely treated at least one FGM survivor in a clinical setting where the cutting would be visible — pelvic exams, pregnancy care, delivery, cervical screening.

A broader estimate using CDC physician visit rates (320.7 office visits per 100 people per year) and the survivor population suggests the total number of physicians who have encountered at least one FGM patient could range from 100,000 to 250,000. I use the OB/GYN figure because it is the cleanest — it comes from an actual survey rather than modeling.

390,214 survivors × 3.207 visits/year = 1,251,416 physician visits/year
1,251,416 ÷ 12 visits per physician = ~104,000 physicians (low end)
1,251,416 ÷ 5 visits per physician = ~250,000 physicians (high end)

Doctors in a position to report

Not every physician who sees an adult survivor has a mandatory reporting obligation. Mandatory reporting is most clearly triggered when a minor is involved. Modeling from the at-risk minor population, the number of direct-patient-care physicians, and the likelihood of clinical contact produces a central estimate of about 30,000 doctors who have been in a position where a mandatory report involving a minor and FGM could reasonably have been expected.

30,000 ÷ 1,032,365 active U.S. physicians = 2.9%
30,000 ÷ 866,460 direct-patient-care physicians = 3.5%

Population denominators

U.S. total population: 341,784,857
Female share: 50.5% → 172,601,353
Minors (under 18): 21.5% → 73,483,744
Girls under 18: 73,483,744 × 0.487 ≈ 35,800,000
Active U.S. physicians: 1,032,365
Direct-patient-care physicians: 866,460

Sources

AHA Foundation/Orchid Project, Female Genital Mutilation/Cutting in the United States (2023); CDC/Public Health Reports, updated estimates (2016); U.S. Census Bureau QuickFacts; AAMC 2025 Key Findings: Physician Specialty Data Report; PubMed, national OB/GYN survey on female genital cutting care experience (2021); CDC/NCHS FastStats, physician office visits; Child Welfare Information Gateway, Mandatory Reporting of Child Abuse and Neglect.

Caveats

The United States does not directly count FGM survivors. Every number above is an estimate derived from indirect methods — ancestry data, country-of-origin prevalence rates, survey responses, modeled visit rates. The survivor count applies source-country prevalence to diaspora populations, which may not reflect actual prevalence among immigrants and their U.S.-born children. The physician estimate relies on a single specialty survey extrapolated to the broader physician population. No national database tracks mandatory reports filed specifically for FGM. I am presenting these numbers because the scale of the gap between estimated physician exposure and known reporting demands the question, not because the numbers are precise.

Where is the mandatory reporting?

If the above math is correct, then even on the low-end, there should be thousands of mandatory reports from physicians around FGM. Where are they?

I don’t have data to answer that. There is no national database tracking mandatory reports filed specifically for FGM. State child protective services agencies track reports by category, but FGM is not consistently broken out as a separate category in most states. The reporting infrastructure is not designed to track this.

But the absence of data is itself informative. Federal prosecutors in United States v. Nagarwala alleged that as many as 100 girls were cut at a single clinic over twelve years. The case was discovered not because a physician filed a mandatory report but because of a tip to law enforcement. No medical organization I contacted would say that physicians who perform FGM on children should lose their medical licenses. The American Medical Association condemned FGM in the abstract but declined to say whether the specific physicians charged should be disciplined. The Federation of State Medical Boards refused to condemn genital cutting on children. Eight other organizations did not respond at all.

If the estimates are even roughly correct, the scale of the gap is difficult to explain as anything other than systemic. Thirty-one thousand minors at risk. Thirty thousand physicians in positions to report. A practice that is a federal crime under the STOP FGM Act of 2020 and illegal in most states. Yet a near-total absence of reporting.

The Michigan case I’ve documented provides one answer for how this happens. A licensing board authorized an investigation and then never assigned an investigator. An attorney general’s office recommended closure while the evidence was still being gathered. A complaint calling the practice “torture” was dismissed through a citation to a file that had no investigative authority. Board members were not even notified of the outcome. Two physicians whose case generated the first federal FGM prosecution in American history now practice together at a clinic in Detroit, accepting patients, their licenses renewed without review.

That is one state. One case. Two physicians. And it took more than a hundred FOIA requests, multiple appeals, and a six-month investigation to document what happened. If the system failed that completely for a case that made national headlines, the question is: What is happening with the thousands of cases that didn’t?

Is there a systemic failure to report female genital cutting by those in the medical system? No one has investigated that question yet.

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In an email on July 29, Dr. Janine Young, the lead author of the American Academy of Pediatrics’ clinical standard on female genital mutilation, stated that “anyone who performs any medically unnecessary treatments on a child” should be thoroughly investigated by the medical board. She did not limit the statement to FGM.

Asked what determines whether a procedure is medically unnecessary, she said, “I assume that this would be determined by the medical board of each state.” Michigan’s state medical board investigated the physicians charged in America’s first federal FGM prosecution and closed the investigation with no action.

Dr. Janine Young is a Professor of Pediatrics at UC San Diego, Division Chief of Academic General Pediatrics, Developmental-Behavioral Pediatrics and Newborn Medicine, and the Martin T. Stein Endowed Chair in Developmental-Behavioral Pediatrics. She is the lead author of “Diagnosis, Management, and Treatment of Female Genital Mutilation or Cutting in Girls,” published in Pediatrics in August 2020 and reaffirmed in January 2026. It is the AAP’s only clinical standard on FGM in children.

I contacted the AAP in June about the continued licensing of two physicians charged in United States v. Nagarwala, America’s first federal FGM prosecution. Dr. Jumana Nagarwala (License No. 4301071795) and Dr. Fakhruddin Attar (License No. 4301067384) hold active, unrestricted Michigan medical licenses today. The state investigations into their licenses were closed before the federal court ruling. Neither physician was convicted. The federal district court held the FGM statute unconstitutional in 2018, and the case was dismissed in 2021.

The AAP responded by sending Young’s clinical report. It did not answer any questions about whether these physicians should retain their licenses.

Nicole Warren, an Associate Professor at Johns Hopkins University School of Nursing and Women’s Health Director at the HEAL Refugee Health and Asylum Cooperative, referred me to Young as the report’s author. Warren described Young as having “wrote the AAP guidelines” and suggested she “may have input.”

I contacted Young on July 28, identified myself as a journalist, provided the case context, noted the AAP’s non-response, and asked three questions.

1. Was she aware that both physicians hold active, unrestricted licenses?

“No, I was not aware of this.”

2. Does the report contemplate what should happen to a provider’s license when they perform FGM on children?

“In my personal opinion as a pediatrician and lead author of the AAP report, I believe that anyone who performs any medically unnecessary treatments on a child should be thoroughly investigated by the medical board in that state and that the state should follow a structured disciplinary process.”

Young framed the answer as her personal opinion, separating herself from the AAP as an institution. The question asked about FGM. Her answer referred to “any medically unnecessary treatments.”

3. Did the 2026 reaffirmation involve any review of this case?

“I was not involved in the reaffirmation process so I do not know the answer to that question.”

On August 10, I asked Young what determines whether a procedure is medically unnecessary. She replied the same day:

“I assume that this would be determined by the medical board of each state. So, if I saw a patient who had FGC performed and they or guardian told me that the Fgc was done by X doctor in X state, I would immediately report that doctor to the medical board.”

Young’s report defines FGM/C as involving “medically unnecessary cutting of parts or all of the external female genitalia.” The report uses the term as its definitional boundary. Asked who determines what that term means, the lead author said state medical boards.

Michigan’s Bureau of Professional Licensing opened an investigation into Nagarwala’s medical license. It closed investigation 43-XX-146153 on September 25, 2018, with no disciplinary action. It opened an investigation into Attar’s license. It closed investigation 43-XX-146259 on July 27, 2018, with no disciplinary action. Both physicians hold active, unrestricted licenses today.

The Federation of State Medical Boards, the national organization representing every state medical board in the country, declined to condemn licensing physicians who performed genital cutting on children. The AMA condemned FGM in the abstract but deferred to the FSMB on licensing. The AAP sent Young's report. Across eleven medical organizations and professional bodies contacted for this investigation, none said that female genital cutting on children should cost a physician their medical license. Young is the first person in any of these organizations to state, in writing, that physicians who perform medically unnecessary procedures on children should face investigation and a structured disciplinary process.

On August 13, I asked a follow-up: “You said the determination of medical necessity would be made by the medical board of each state. Does that mean it is up to each state medical board to determine what medical procedures are and aren’t necessary?” She did not reply.

The report is twenty-six pages. It covers CPS reporting requirements, criminal statutes, asylum law, ICD-10 coding, defibulation procedures, community engagement strategies, vaccination protocols, mental health referrals, and detailed case examples. It discusses the Nagarwala prosecution by name, noting the Department of Justice “prosecuted its first case against a US physician accused of having performed FGM/C across state lines in up to 100 children” and that “the charges were dismissed by the district judge of the Eastern District of Michigan.”

The report does not contain the word “license” or discuss what should happen to the performing physician’s credential. Every enforcement mechanism it names runs through criminal law, child protection, or immigration. None addresses the medical licensing board.

In her email, Young stated that physicians who perform medically unnecessary procedures on children should be investigated and disciplined by the state medical board. The report does not say this. Asked what determines medical necessity, she said the state medical board determines it. A state medical board investigated and closed with no action.

Multiple national medical associations, including the Royal Dutch Medical Association, the Danish Medical Association, the British Medical Association, and the Canadian Paediatric Society, have stated that routine circumcision of male children is not medically necessary. The AAP’s own 2012 policy on circumcision, which found benefits outweigh risks, expired in 2017 without reaffirmation. The AAP currently has no active policy position on whether circumcision is medically necessary. The author of their FGM policy statement says that doctors should be "thoroughly investigated" and that the “state should follow a structured disciplinary process” for “medically unnecessary treatments on a child.”

The AAP’s own World Health Organization classification table, reproduced in Young’s report, categorizes FGM into four types and subtypes. Type Ia is defined as “removal of prepuce only.”

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State records show that Michigan’s licensing agency closed its investigation into Nagarwala before the federal case ended, never investigated Attar at all, told the press both investigations were active when its own files show they were closed, and renewed Nagarwala’s license in seven minutes. I obtained the records through more than one hundred Freedom of Information Act requests.

The federal case began when the FBI arrested Nagarwala in April 2017 and charged her with performing genital cutting on young girls at a Michigan clinic owned by Attar. Agents identified nine victims between the ages of seven and thirteen. Prosecutors estimated that as many as 100 girls may have been cut over twelve years. Attar acknowledged to agents that Nagarwala treated girls ages six to nine at his clinic after hours.

The case never reached a jury. Judge Bernard Friedman ruled the federal FGM statute unconstitutional in November 2018 and dismissed the FGM charges. The ruling addressed the law, not the physicians’ conduct. No party in the case disputed that procedures were performed on the girls. Congress repaired the statute with the STOP FGM Act of 2020, but the fix could not apply retroactively. The only disciplinary avenue left was to take the doctors’ medical licenses. However, Michigan had already closed its licensing investigations before the federal court ruling.

Michigan’s Board of Medicine wanted an investigation. Within days of the arrests, five board reviewers unanimously authorized an investigation into Nagarwala. Board reviewers authorized an investigation into Attar three days later. Dr. Peter Graham went further, writing on Attar’s file: “I approve investigation. Please also refer to Director Gaedeke for summary suspension, which I approve.” Dr. James Sondheimer wrote: “Agree with proceeding with investigation. Res ipsa loquitur.” The facts speak for themselves.

The Michigan Department of Licensing and Regulatory Affairs (LARA), the agency that executes the board’s decisions, never carried out the suspension. It never assigned an investigator to Attar. State records certify that “a traditional investigation was not conducted” on Attar. The doctor who owned the clinic, and who told federal agents that girls were treated there after hours, was never investigated by the state.

The Nagarwala investigation consisted of one attempted witness interview. LARA investigator Jennifer Pappas contacted Dr. Dena Nazer, a child abuse pediatrician, to arrange an interview. Two days later, federal prosecutor Sara Woodward called Pappas and blocked the interview. Pappas submitted her investigation report the same day. No further investigative activity occurred. The state never interviewed another witness.

What ended the cases was a recommendation from the Attorney General’s office. Assistant Attorney General Bridget K. Smith authored closure memos for both physicians on the same day in July 2018. The substantive content of both memos is redacted in full. LARA closed the Nagarwala investigation that September with the disposition “No Action Taken.” The federal charges were still pending. Trial was scheduled for January 2019. LARA closed the Nagarwala file two months before the FGM charges were dismissed. The Attorney General recommended closing Attar’s file four months before.

When asked, the agency told the press that closed investigations were still active. In December 2018, Medscape reported that both licenses were “active but under investigation” and that LARA “could not comment further on active investigations.” LARA’s own records show both investigations had been closed. Internal LARA emails show senior officials, including Bureau of Professional Licensing Director Cheryl Wykoff Pezon, Division Director Jon Campbell, Cynthia Rowe, and Forrest Pasanski, coordinating the agency’s response to the Medscape inquiry.

A physician who tried to raise the alarm got the same treatment. In June 2019, a board-certified anesthesiologist filed a complaint against Nagarwala, writing that she had “apparently performed over 100 surgeries without anesthesia, over the past 10 years” and that the practice “amounts to torture, for which we forbid on death row inmates.” LARA dismissed the complaint, telling the physician the concerns were “being addressed” in file COMxx-146169. That file was a criminal monitoring file with no investigative authority, opened to passively track a federal case whose FGM charges had been dismissed over a year earlier. LARA said nothing about the civil investigation file, 43-XX-146153, which it had already closed with “No Action Taken.”

Nothing in Michigan’s licensing system has checked either license since. When Nagarwala renewed her license in April 2026, she submitted her application at 12:53 PM and received her confirmation email at 1:00 PM. The renewal record contains only what she submitted and automated system emails. No complaint history check. No compliance screening. No human review. The renewal form asks about convictions, not charges or investigations, so she was not required to disclose the federal case. Her license runs through June 19, 2029.

Michigan never held a single administrative hearing on either license. The Michigan Office of Administrative Hearings and Rules, the body that adjudicates physician discipline, has zero proceedings on file for either physician.

The legislature handed the agency new authority to act. When legislators considered Senate Bill 410, which required permanent license revocation upon conviction for FGM, LARA’s official position was “No position.” The bill passed the House 105-2 and the Senate 38-0. Governor Rick Snyder signed it as part of a package of twelve anti-FGM bills. LARA used neither the authority it told the legislature it already had nor the new authority the legislature provided.

Both physicians returned to practice. In August 2022, Attar reopened his clinic under a nearly identical name at a new address in Farmington Hills. The practice kept the same phone number. The authorized official on the federal provider registry is Farida Attar, who was charged in the federal case.

Nagarwala and Attar also registered a new practice together: Livernois Primary and Urgent Care at 18254 Livernois in Detroit. Nagarwala is the founder. Attar is staff. The clinic advertises school physicals, sports physicals, camp physicals, and childhood immunizations. It accepts Medicaid, Medicare, and other taxpayer-funded insurance. Neither physician’s biography on the clinic’s website mentions the federal prosecution.

Patients encounter these physicians without knowing their history. In May 2025, a patient treated by Nagarwala at Garden City Hospital filed a complaint against her. Nothing on Nagarwala’s public license record indicates her history. The patient had no way of knowing who their doctor was.

The documents that would explain the state’s decisions remain sealed. The Attorney General’s closure memos are withheld in full under attorney-client privilege. On May 18, 2026, LARA and the Attorney General’s office each denied FOIA appeals seeking the memos, on the same day, using similar language. Both denials placed the word “appeal” in scare quotes. Neither addressed the argument that the statute requires agencies to separate privileged legal analysis from releasable factual content.

No Governor has addressed LARA’s handling of the cases. No legislator has called for an oversight hearing. The House Oversight Committee has subpoena power over LARA. It has not used it. Both licenses remain active. Both closure memos remain sealed. No one in state government has answered for either.

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• Read the full timeline of this investigation here.

• Support this investigation here.

Disclosure: I filed a defamation lawsuit against Bruchim in 2023; it was dismissed in 2024. The reporting below is based on public records, published scholarship, and direct correspondence.

Dr. Dena S. Davis, the lead author of the American Academy of Pediatrics’ retracted 2010 policy recommending physicians offer a “ritual nick” on girls’ genitals, wrote peer-reviewed scholarship on Brit Shalom in collaboration with members of Bruchim, a Jewish nonprofit that advocates for non-circumcising families. Her name does not appear anywhere on the organization’s public platforms, including their website, podcast, or press releases.

The paper, “B’rit shalom: a Jewish ritual alternative to newborn male circumcision,” was published in the International Journal of Impotence Research, a Nature-family journal, in 2023. The byline lists Max DuBoff, Bruchim’s Director of Education and a board member of Bruchim, and Dena S. Davis, the lead author of the AAP ritual nick policy. The paper cites Davis’s ritual nick scholarship in its references.

The acknowledgments thank Eliyahu Ungar-Sargon, Lisa Braver Moss, and Rebecca Wald, Bruchim’s founders, and Max Buckler, Bruchim’s “Bioethics Researcher.” Braver Moss and Wald are cited as sources in the paper, which quotes “conversation between authors and Lisa Braver Moss and Rebecca Wald, August 2, 2021.” The reference list also cites Bruchim’s website, Rebecca Wald’s blog Beyond the Bris, Lisa Braver Moss, and Rebecca Wald’s book Celebrating Brit Shalom, and Ungar-Sargon’s documentary Cut. DuBoff’s competing interests disclosure in the paper states he is a board member of Bruchim. Davis declares no competing interests.

On July 4, 2026, I submitted a request to the International Journal of Impotence Research asking the editors to review whether the competing interests disclosures on this paper meet the journal’s published standards.

Bruchim’s website does not disclose their relationship to Davis. A search of her name on their website, team page, podcast, press releases, and Beyond the Bris Substack written by Bruchim’s executive director Rebecca Wald, produced zero results, despite her paper being the primary scholarship done on Brit Shalom, the circumcision-alternative promoted by Bruchim.

When Bruchim leadership appeared at the 2023 Ritualwell panel “Brit Beyond Milah,” the event description called DuBoff “the lead author” and did not mention Davis. The paper’s author contribution statement states that Davis wrote the first draft of the paper: “DSD [Dena S. Davis] wrote the initial version of the article. MD [Max DuBoff] rewrote and reorganized the article.”

Davis also confirmed in emails with me that she wrote the initial version of the paper. She described the differences between her first draft and Max DuBoff’s rewrite as stylistic — “not my style” — rather than ideological and said it “left out a lot of the human interest stuff.” Davis said the final paper “does not misrepresent me but it’s very different than I would have written it.”

When I asked Davis if her 2023 brit shalom paper represented a change or "a continuation of the same perspective" that produced the 2010 ritual nick paper, she replied, "No, I don't think the Brit Shalom paper was a change."

She also said that she “did not think AAP should have retracted the policy statement” in which she advocated that doctors should be allowed to perform a ritual nick of little girls genitals for families who want female genital cutting. “Still don’t.”

In their previous writing, Davis and Wald describe the same regulatory approach to male genital cutting:

• Davis, 2001: “Nonphysician ritual practitioners of MGA should be certified. The state regulates the hygienic practices of the people who cut our hair and our fingernails, so why not a baby’s genitals?”

• Wald, 2026: “What regulation can do is ensure that when brit milah is performed, it is performed safely: with proper training, sterile conditions, and clear protocols for when medical care is needed.”

Wald has previously argued against a full criminal ban on male genital cutting in multiple articles. Wald did not respond to a request for comment when asked if she also opposes a ban on female circumcision.

The paper appeared in a special collection titled “Genital Cutting and Surgery in Children: Part Two,” guest-edited by bioethicist Brian D. Earp. Earp holds affiliations at Yale, Oxford, and the National University of Singapore. He has co-authored with Bruchim’s Max Buckler, appeared on the Bruchim Podcast, and leads the Brussels Collaboration on Bodily Integrity, which includes Bruchim leadership team member David Balashinsky. Davis told me the collaboration with DuBoff was arranged by the journal after her solo paper was rejected. She said she “didn’t know the Brit Shalom people” before writing the paper.

This paper is not the only connection between Bruchim and Davis. In 2023, Buckler co-authored a paper with Brian Earp and Lori Bruce in Current Sexual Health Reports: “From Intimate Exams to Ritual Nicking: Interpreting Nonconsensual Medicalized Genital Procedures as Sexual Boundary Violations.” The acknowledgments thank Davis for “discussions and/or comments.” Buckler’s competing interests disclosure in that paper states he is “affiliated with Bruchim.”

Bruchim did not issue a press release for the paper Davis drafted. It did issue a press release through EINPresswire for Buckler’s “As controversies mount, circumcision policies need a rethink” in the Journal of Medical Ethics in November 2025.

The Buckler paper that received Bruchim’s press release reported the results of two months of recorded interviews with Dr. Douglas Diekema and Dr. Andrew Freedman, both members of the AAP’s 2012 Task Force on Circumcision, that produced a policy statement declaring that the health benefits of male circumcision outweigh the risks. Diekema chaired the AAP Committee on Bioethics, the same committee that published the 2010 policy on female genital cutting where Davis served as lead author.

In those interviews, Diekema told Buckler he doesn’t believe the data supports saying benefits outweigh the risks. Freedman called the AAP policy a “permission slip” and said the AAP should “get out of the business” of circumcision. He said circumcision is “not really a medical practice” and that “there is nothing wrong with the penis.”

Freedman has stated publicly that he circumcised his own son at the family’s kitchen table. Wald reported this detail across multiple Beyond the Bris articles without criticism. In her article “These Jewish Doctors Tried to Stop America’s Circumcision Train“ she presents him as anti-circumcision, placing him alongside intactivists like Paul Fleiss and Dean Edell, and attributes routine circumcision to Christians. In “On Eric Clopper and Misdirected Anger“ (2018), Ungar-Sargon published a defense of Freedman, calling him “a man with whom I disagree, who is clearly able to distinguish between his medical opinion on the one hand and his religious beliefs on the other.”

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On June 25, I sent requests for comment to the following Bruchim figures: Lisa Braver Moss (President), Rebecca Wald (Executive Director), Eliyahu Ungar-Sargon (Founding Executive Board), Max DuBoff (Director of Education), and Max Buckler (Bioethics Researcher). After giving them a week to respond, I sent a follow-up email July 2, letting them know they would need to respond within a day if they wanted any comment included. I also called a publicly listed number for Bruchim and left a message.

None responded. Screenshots of the requests for comment are below:

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No member of the organization answered the question “Do you consider yourself an intactivist?”

Previous public statements indicate that the answer in most cases is no:

• Lisa Braver Moss has said that “Bruchim is not an intactivist organization, because convincing Jewish people not to circumcise isn’t our main objective.”

• Max Buckler says he does not identify as an intactivist.

• Rebecca Wald has said she prefers to label herself a ‘circumcision critic’ or ‘circumcision questioner.’”

• Eliyahu Ungar-Sargon said in an interview with James Loewen, “I don’t call myself an intactivist” but that he shares the intactivist position.

While publicly declining the intactivist label, publicly listed members of Bruchim hold overlapping roles across genital-autonomy organizations.

• David Balashinsky is listed on Bruchim’s leadership team as Outreach & Advocacy, as a Board Member and Co-founder of GALDEF, and on Doctors Opposing Circumcision’s Board of Directors and Advisors. He has spoken at the Worldwide Day of Genital Autonomy in 2020, 2022, and 2023.

• Lisa Braver Moss is Bruchim’s President and Co-Founder and appears on Your Whole Baby’s Advisory Board. She has presented at genital-autonomy symposiums and conferences in 1991 and 2014.

• Bruchim’s team page lists Elana Johnson as Bruchim’s Social Media Manager and says: “Additionally, Elana serves as one of the Directors of Equity for Your Whole Baby.” Your Whole Baby’s Equity Commitment page directly points readers to Bruchim and to a statement authored by Bruchim leaders.

• Bruchim’s Physician Advisor, Leif Thompson, is listed under Doctors Opposing Circumcision’s Board of Directors and Advisors, spoke at WWDOGA 2024, and also appeared at the 2026 Intact Global Conference.

• Mark D. Reiss, who died in late 2025, served as DOC’s Executive Vice President for over 25 years and on Intact America’s Board of Health Professionals. His Celebrants of Brit Shalom directory, the network cited in the DuBoff/Davis paper, is now incorporated into Bruchim’s Inclusion Directory.

• Eliyahu Ungar-Sargon presented at Intact America’s 2022 conference and 2026 Intact Global Conference in Los Angeles.

• Multiple intactivist individuals and organizations signed a “Statement Opposing Antisemitism Within The Genital Autonomy Movement” authored by Bruchim leadership, including David Balashinsky, Rebecca Wald, Lisa Braver Moss, and Eliyahu Ungar-Sargon.

Eliyahu Ungar-Sargon has described the genital autonomy movement as “a breeding ground for antisemitism, Islamophobia, misogyny, and misinformation” and characterized its members as “white, aggrieved men” who “have always been the bull’s eye for fascists.” Ungar-Sargon did not respond to a request for comment. No other Bruchim member responded to a request for comment.

No Bruchim member answered the question: “Does Bruchim have a policy regarding communication, coordination, or funding relationships with organizations that advocate for circumcision or oppose the genital autonomy movement?”

In a previous interview with James Loewen, Eliyahu Ungar-Sargon explicitly cites the ritual nick and double standard between male and female genital cutting as an argument against circumcision.

Davis has said that “the ritual nick is a good way to equalize male and female, but it would be even better, in my opinion, not to do it at all.” No member of Bruchim responded to a request for comment on whether they agree with Davis’s statements or have a position on the ritual nick policy.

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If you are someone who has been waiting for what you can do to make a difference on this issue, now is the time to act.

Below are some resources, updates, and suggestions.

Share This Medium Article

One piece of feedback I received is that checking my research might be difficult for a journalist unwilling to file their own freedom of information act requests and that casual readers might not be willing to go through the full timeline I published.

To solve this, I wrote a short version of the story on Medium:
https://medium.com/@hegemonmedia/fgm-doctors-hold-medical-licenses-and-practice-together-at-detroit-clinic-dbc3a854f825

The medium version uses only publicly available information and is written in a short to-the-point style with glossy photos. This is designed for casual readers and journalists who don’t want to have to independently verify FOIA requests.

All they have to do to see what I’ve written is true to is click links.

Where You Can Share

Here are some suggestions for where you can share the article:

• Reddit: r/Detroit, r/MetroDetroit, r/Michigan, r/Lansing, r/Dearborn, r/AnnArbor, r/grandrapids, r/flintmichigan, r/bioethics, r/Ethics, r/TwoXChromosomes, r/Feminism, r/fourthwavewomen, r/AskFeminists, r/Intactivism, r/Intactivists, r/TrueCrimeDiscussion, r/medicine

• Facebook Groups: Detroit Community, 24/7 Only in Detroit News Group, Detroit Community Event Calendar, The Detroit Scanner’s Community Outreach, Newspaper Friends, Politics in Lansing, Michigan Democratic Progressives, Michigan Resistance, Ann Arbor Politics, Ann Arbor Townies — Politics, Sterling Heights City Politics, Dearborn Heights Civic Discussion, Women of Metro Detroit, All Things Michigan, Patient Safety Action Network Community, Ethics in Medicine, Healthcare Ethics Consultant, Speak Out on FGM

• Local News / Investigative Tips: BridgeDetroit, Outlier Media, WDIV / Local 4 Contact, WXYZ 7 Action News Contact, CBS News Detroit Tips, Detroit Metro Times Tips, Planet Detroit Contact, Michigan Public Contact, Bridge Michigan Contact, Michigan Advance Contact, The Michigan Independent Contact, Axios Detroit, Axios Tips

  Anti-FGM Organizations: U.S. End FGM/C Network, Sahiyo, Equality Now, Global Woman P.E.A.C.E. Foundation, AHA Foundation, Sanctuary for Families, Safe Hands for Girls

  Patient Safety / Medical Accountability: Patient Safety Action Network, Patients for Patient Safety US

  Regulatory / Public Accountability: Michigan LARA Licensing Complaint, LARA Health Professional Complaints, Michigan Board of Medicine Agendas and Minutes, Joint Commission Patient Safety Concern

  Other Platforms / Forums: X / Twitter, Bluesky, Threads, Substack Notes, Mastodon, Medium FGM Tag, DetroitYES Forum, City-Data Detroit Forum, Patch Detroit, Nextdoor

Challenges Sharing

I’ve struggled to share this article. Some examples:

• I posted the article on reddit. A pop-up suggested I crosspost. I did. It removed the post for spamming. Many reddits also don’t allow crossposts or certain content, despite their users being interested in this news.

• I posted on Facebook. It suggested I boost it. I did. It refused the ad for potential “election interference.” (I’d love to know what election could change this issue.)

• I posted a video on TikTok. It blocked it for community guidelines violations. Reversed on appeal, but delayed the video a day.

I’m sure these are automated systems, not targeted suppression, but the impact is the same. It’s frustrating. If you’re experienced with these platforms, please share your solutions in the comments and use them to show us how it’s done.

More Suggestions

At the end of my timeline article, that collects all information from my investigation, there is a “Next” section on what could happen next that includes some possibilities for activists. That section has even more ideas.

Michigan Residents

Your elected representatives can change this. The Governor of Michigan is Gretchen Whitmer. The oversight committee is chaired by Rep. Jay DeBoyer. Both of these officials could act. Respectfully let them know you want them to investigate.

Sample email you could send:

I am writing to ask you to investigate the Michigan Department of Licensing and Regulatory Affairs’ handling of the medical licenses of Dr. Jumana Nagarwala and Dr. Fakhruddin Attar, two doctors charged in United States v. Nagarwala, the first federal FGM prosecution in U.S. history.

The doctors did not dispute that they had engaged in female genital mutilation. Federal charges were dismissed on constitutional grounds in 2018. However, no conviction was required for Michigan to take licensing action, because the Public Health Code allows discipline based on conduct, not just criminal outcome.

LARA closed its licensing investigation with no disciplinary action before the federal court ruling. Neither physician was suspended, reprimanded, or restricted in any way. Both hold active, unrestricted Michigan medical licenses today. Both are currently practicing together at the same Detroit clinic, advertising school physicals and receiving state funds through medicaid.

The memos explaining why the state closed its investigation have been withheld from public disclosure. No one outside LARA and the Attorney General’s office has explained to the public why they closed their investigation while these doctors were being federally prosecuted. LARA has lied to the press about its actions, by claiming in a statement to Medscape that they were investigating, when they were not.

A detailed account of these facts, sourced to public records and documents obtained through FOIA, is available here: https://www.hegemonmedia.com/p/how-doctors-prosecuted-for-fgm-kept

Find out why this happened and ensure it does not continue.

Support Legal Action

I am exploring legal challenges to make public the memos explaining why the state closed its licensing investigation. Those will cost money. If you want to support that, contribute here:

GoFundMe: Expose Medical Board for Licensing an FGM Doctor

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Dr. Jumana Nagarwala and Dr. Fakhruddin Attar were charged in 2017 in the first federal prosecution of female genital mutilation in United States history. Both hold active, unrestricted medical licenses issued by the State of Michigan. They now practice together at a Detroit clinic that advertises school physicals and accepts Medicaid.

Michigan’s licensing agency closed its investigation into Nagarwala on September 25, 2018, two months before the federal charges were dismissed. The Attorney General recommended closing Attar's case on July 27, 2018, four months before. State records certify that no traditional investigation was ever conducted into Attar. Both cases were closed with no disciplinary action.

Every fact in the timeline below is sourced to state licensing files, Attorney General records, internal agency communications, federal court documents, public record, or on-the-record statements. I obtained the non-public records through more than a hundred Freedom of Information Act requests.

Summary

• Michigan's Board of Medicine unanimously authorized an investigation into Nagarwala and recommended emergency suspension for Attar.

• The state never executed the suspension and never assigned an investigator to Attar’s case.

• The only witness interview attempted in Nagarwala’s investigation was blocked by the federal prosecutor.

• The Attorney General recommended closing both cases while the federal trial was still scheduled.

• LARA told the press both investigations were “active” months after its own records show they were closed.

• When a physician filed a new complaint in 2019, LARA dismissed it by citing a monitoring file with no investigative authority, saying nothing about the civil investigation it had already closed.

• Every medical organization asked about the case — including the AMA, the AAP, and the Federation of State Medical Boards — declined to say that physicians who cut the genitals of children should lose their medical licenses.

• The lead author of the AAP’s retracted 2010 ritual nick policy says it should never have been retracted.

• The memos explaining why the state closed both investigations remain sealed.

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Timeline

September 30, 1996 — Congress criminalizes FGM.

President Clinton signs the Illegal Immigration Reform and Immigrant Responsibility Act, which includes 18 U.S.C. § 116, making it a federal crime to circumcise, excise, or infibulate the genitalia of any female under 18. The maximum penalty is five years in prison. The law provides no exception for custom or ritual.

2001 — A law professor argues the federal FGM statute is constitutionally vulnerable.

Dena S. Davis publishes “Male and Female Genital Alteration: A Collision Course with the Law?” in Health Matrix at Case Western Reserve. Davis argues that the federal FGM statute is vulnerable because it bans all genital alteration on girls — “no matter how minimal the surgery or how safe and sanitary the procedure” — while leaving male circumcision untouched. Her recommendation: “Federal and state laws should be rewritten to allow the sort of minor genital nick.” The article calls the disparity “unacceptable on First Amendment grounds.”

April 26, 2010 — The American Academy of Pediatrics (AAP) proposes legalizing a “ritual nick” of girls genitals.

The AAP’s Committee on Bioethics publishes “Policy Statement—Ritual Genital Cutting of Female Minors“ in the journal Pediatrics. The lead author of the statement was Dena S. Davis, who cites the constitutional argument she published nine years earlier.

The statement suggests that since “some forms of FGC are less extensive than the newborn male circumcision” federal and state laws should be changed to “enable pediatricians to reach out to families by offering a ritual nick.” The AAP compares the nick to an ear piercing.

The statement is retracted in just twenty-six days due to public outcry. However, the retraction is not the result of its author changing her mind. Dena S. Davis, the author of the statement told me that she “does not think AAP should have retracted the policy statement--still don’t.”

The policy statement had revealed the medical establishment’s willingness to accommodate genital cutting on girls within a clinical framework. The retraction showed it could not do so publicly.

April 2017 — The first federal FGM case begins.

The FBI arrests Dr. Jumana Nagarwala, an emergency room physician, and charges her with performing female genital mutilation on young girls at a clinic in Livonia, Michigan. The clinic is owned by Dr. Fakhruddin Attar. His wife, Farida Attar, is charged with assisting during the procedures. Federal prosecutors call it the first federal FGM case in U.S. history, twenty-one years after Congress passed the law.

The FBI identifies nine victims between the ages of seven and thirteen from Michigan, Minnesota, and Illinois. One girl tells agents she had been told they were going to the doctor because “our tummies hurt.” When agents interview Attar, he acknowledges that Nagarwala treated girls ages six to nine at his clinic, that she came only after hours on Fridays and Saturdays, performed the procedures for free with no paperwork, and did so five or six times per year. Prosecutors estimate as many as 100 girls may have been cut at the clinic over a twelve-year period.

April 18, 2017 — Michigan’s Board of Medicine authorizes an investigation into Nagarwala.

Five board reviewers unanimously authorize an investigation into Nagarwala’s medical license (complaint file 43-XX-146153). The same day, a Michigan Department of Licensing and Regulatory Affairs (LARA) analyst opens a separate criminal monitoring file (#146169) to passively track the federal prosecution. Two files now exist on the same physician — one for the state’s own civil licensing investigation, one to monitor the federal case.

April 21, 2017 — The Board authorizes an investigation into Attar and recommends emergency suspension.

Board reviewer Dr. Peter Graham writes on Attar’s file (43-XX-146259): “I approve investigation. Please also refer to Director Gaedeke for summary suspension, which I approve.” Board reviewer Dr. James Sondheimer, a professor of medicine at Wayne State University, writes: “Agree with proceeding with investigation. Res ipsa loquitur” — a legal term meaning “the facts speak for themselves.”

The Michigan Department of Licensing and Regulatory Affairs (LARA) never executes the summary suspension. It never assigns an investigator to Attar’s case.

June 2017 — LARA takes “no position” on a bill to revoke FGM doctors’ licenses.

Senate Bill 410 would require permanent revocation of a health professional’s license upon conviction for female genital mutilation. LARA’s enrolled bill analysis records the agency’s official stance: “ADMINISTRATION POSITION: No position.”

The same document identifies the Nagarwala and Attar case by name. Internal emails show the decision was deliberate. On June 13, 2017, Marnie Wills, Deputy Director of LARA's Office of Policy and Legislative Affairs, wrote to colleagues: “I let her know we will have no position.”

July 11, 2017 — Governor Snyder signs Michigan’s anti-FGM laws.

Governor Rick Snyder signs a package of twelve bills criminalizing FGM under Michigan state law. The package increases the maximum penalty to fifteen years in prison — triple the federal penalty. It requires automatic license revocation upon conviction. It makes parental consent no defense. It makes custom or ritual no defense. Michigan becomes the twenty-sixth state to ban FGM.

The bill passes the Michigan House 105-2 and the Senate 38-0. LARA uses neither the authority it told the legislature it already had, nor the new authority the legislature provided.

September 29, 2017 — The federal prosecutor blocks the state’s only witness interview.

LARA investigator Jennifer Pappas contacts Dr. Dena Nazer, a board-certified child abuse pediatrician at Kids TALK Medical Center whose job is evaluating children suspected of being maltreated. The interview has been requested by the Assistant Attorney General’s office itself. Nazer responds that she will forward the request to her attorneys.

Two days later, U.S. Assistant Attorney Sara Woodward, the lead federal prosecutor on the FGM case, calls Pappas directly. Woodward tells the state investigator that Nazer “will not be providing a statement to our Bureau due to the pending Federal Court Case and due to WITNESS NAZER’s limited knowledge about the licensee’s activities.”

Pappas submits her investigation report the same day. It documents no further investigative activity. The state never interviews another witness in the case. Ten months later, the Attorney General recommends closing the investigation.

July 27, 2018 — The Attorney General recommends closing the Attar investigation.

Assistant Attorney General Bridget K. Smith authors a “Request to Close File” memo for Attar’s case (43-XX-146259), addressed to Cheryl Wykoff Pezon, then Director of LARA’s Bureau of Professional Licensing. The substantive content is redacted in full. LARA receives the memo on August 7, 2018.

No investigation into Attar is ever conducted. LARA later confirms under FOIA: “A traditional investigation was not conducted under 43-XX-146259.” Michigan’s Board of Medicine authorized an investigation and recommended emergency suspension. No investigator was assigned. No suspension was executed. No hearing was held. The Attorney General closed a file the state never opened.

Smith authors a parallel closure memo for the Nagarwala investigation the same day. The federal case is still active. Trial is scheduled for January 2019. The state does not wait for it to conclude.

September 25, 2018 — LARA closes the Nagarwala investigation.

Two months after Smith recommended closure, LARA closes civil investigation file 43-XX-146153. The complaint history printout records the disposition: “No Action Taken.” The federal case will not be resolved for another two months.

Eight days earlier, LARA Division Director Jon Campbell emailed staff: “Please add this to the criminal file – 146169. It appears the investigative file is being closed until witnesses can testify on behalf of the department, thus, this is the only remaining file under the criminal charges.”

November 20, 2018 — A federal judge strikes down the FGM law.

U.S. District Judge Bernard A. Friedman rules that 18 U.S.C. § 116 — the federal FGM statute Congress passed in 1996 — is unconstitutional. In a 28-page opinion, Friedman writes that Congress “overstepped its bounds” and that FGM is “’local criminal activity’ which, in keeping with longstanding tradition and our federal system of government, is for the states to regulate, not Congress.”

The ruling dismisses the FGM charges against both physicians. It addresses the law, not the physicians’ conduct. No party in the case disputes that procedures were performed on the girls.

Friedman’s opinion includes this passage: “The government’s suggestion that ‘those seeking the procedure [can] travel to refuge states where the practice is not prohibited’ is simply false. No state offers refuge to those who harm children.”

Michigan closed its own investigations before this ruling. The Nagarwala investigation ended two months earlier. The Attar closure was recommended four months earlier. The collapse of the federal case did not cause the state’s inaction.

December 10, 2018 — LARA lies to the press by claiming both investigations are still active.

Medscape publishes an article reporting that both physicians’ licenses are “active but under investigation” and that LARA “could not comment further on active investigations.”

LARA’s own records show both investigations had been closed. The Nagarwala investigation closed months earlier with no action taken. No investigation into Attar was ever conducted. Internal LARA emails from December 5 show multiple senior officials — including BPL Director Pezon, Division Director Campbell, Cynthia Rowe, and Forrest Pasanski — coordinating the agency’s response to the Medscape inquiry.

2019 — The Department of Justice declines to appeal. It asks Congress to fix the law instead.

The DOJ does not appeal Judge Friedman’s ruling that the federal FGM statute is unconstitutional. In April 2019, the Department sends a letter to Congress asking lawmakers to amend 18 U.S.C. § 116 to add Commerce Clause language that would survive constitutional challenge. The government that brought the first FGM prosecution in American history declines to defend the law that made it possible.

Remaining charges in the case, conspiracy and obstruction, continue in Friedman’s courtroom.

June 22, 2019 — A physician files a complaint calling the cutting “torture.”

A board-certified anesthesiologist files licensing complaint COM19-001459 against Nagarwala. The complainant identifies themselves as a former Michigan physician with an active California medical license. They write that Nagarwala “has apparently performed over 100 surgeries without anesthesia, over the past 10 years” and say the practice “amounts to torture, for which we forbid on death row inmates.” They implore the Board of Medicine to “take action against this physician.”

The complainant knows the federal case has been dismissed. They are asking the state to use its independent authority to discipline the license.

February 5, 2020 — LARA dismisses the complaint by citing the wrong file.

LARA tells the physician their concerns are “being addressed” in file number COMxx-146169 — the criminal monitoring file, which has no investigative authority. The agency says nothing about civil investigation file 43-XX-146153, which was closed with “No Action Taken” seventeen months earlier.

The criminal monitoring file existed to passively track the federal case. The federal case was dismissed over a year before. LARA cited a file that could not investigate and said nothing about the file that already hadn’t.

After February 2020 — No state agency takes any further action on either physician’s license.

Michigan never holds a single administrative hearing. The Michigan Office of Administrative Hearings and Rules, the body that adjudicates physician disciplinary cases, has zero proceedings related to either physician on file. No investigator is ever assigned to Attar’s case.

January 5, 2021 — Congress passes the STOP FGM Act.

The Strengthening the Opposition to Female Genital Mutilation Act of 2020 (H.R. 6100) becomes law. It amends 18 U.S.C. § 116 to add Commerce Clause nexus language, increases the maximum penalty to ten years, and expands the scope of punishable acts. Section 5 includes a “sense of the Congress” that Judge Friedman’s ruling was wrong.

The law is a direct response to Friedman’s November 2018 decision and the DOJ’s April 2019 letter. It cannot be applied retroactively. Congress has fixed the statute, but the fix comes too late to prosecute the physicians whose case broke it.

September 28, 2021 — Judge Friedman dismisses the remaining charges for vindictive prosecution.

After having the FGM counts dismissed, and then successfully moving to dismiss charges under 18 U.S.C. § 2423 (transport of a minor for criminal sexual activity — a statute Friedman ruled had no reasonable application to FGM), the defendants face a fourth superseding indictment. The government files new conspiracy and witness tampering charges based on the same underlying conduct.

Friedman rules the prosecution vindictive. He writes that “the government obtained the fourth superseding indictment, which asserts new and additional charges, in retaliation for defendants’ past success in having other charges dismissed.” He notes that all remaining charges rely on FGM being a federal offense — which his own earlier ruling declared void ab initio, as if it had never been passed. He dismisses the fourth superseding indictment.

The case is over. No defendant is convicted. The federal system spent four and a half years prosecuting the case and has nothing to show for it. The state system spent eighteen months not investigating and has nothing to show for it either. The question of whether these physicians should hold medical licenses has never been adjudicated by anyone.

March 2022 — Both physicians are practicing together again, at a new clinic advertising services for children.

Nagarwala and Attar register a new practice, Livernois Primary and Urgent Care, at 18254 Livernois in Detroit’s University District neighborhood. The National Provider Identifier is registered on March 24, 2022. Nagarwala is the founder. Attar is staff. Neither physician’s biography on the clinic’s website mentions the federal prosecution.

The last time they worked out of the same clinic was Burhani Medical Clinic in Livonia — where, according to the federal indictment, Nagarwala performed FGM procedures on minor girls while Attar opened his clinic after hours to let her do it.

The clinic’s services page advertises school physicals, sports physicals, camp physicals, and childhood immunizations — services marketed to children and their parents. Its Google listing identifies it as “women-owned,” “Asian-owned,” and “LGBTQ+ friendly.”

The clinic accepts thirteen insurance providers, at least seven of which are taxpayer-funded: Medicaid of Michigan, Medicare of Michigan, UnitedHealthcare Community Plan, Molina Healthcare, Meridian Health Plan, Aetna Better Health of Michigan, and McLaren Medicaid.

August 2022 — Attar reopens his clinic under a nearly identical name at a new location.

The corporate entity that operated Burhani Medical Clinic at the Livonia address, the clinic where federal prosecutors said Nagarwala performed FGM on minor girls, dissolved in May 2021. The remaining federal charges were dismissed in September 2021.

Eleven months later, on August 29, 2022, the NPI record is updated to a new address: 32910 W 13 Mile Road in Farmington Hills. The practice keeps the same phone number. The authorized official on the federal provider registry is Farida Attar, who was charged alongside her husband as a co-defendant in the federal case.

The new clinic advertises sports physicals and care for patients of “every age group.” It accepts Medicare, Medicaid, and major commercial insurers. Private physician offices are exempt from facility licensing in Michigan. There was no facility license to revoke, no facility-level inspection triggered by the federal charges, and no regulatory mechanism to prevent the same practice from reopening under a nearly identical name. The only oversight ran through the individual physicians’ medical licenses, which the state never restricted.

May 17, 2025 — A patient files a complaint against Nagarwala.

A patient who is treated by Nagarwala in the emergency room at Garden City Hospital in Westland, Michigan files a licensing complaint alleging she improperly administered a drug injection following a car accident. The patient had no way of knowing who their doctor was. Nothing on Nagarwala’s public license record indicates her history.

Garden City Hospital, asked to comment, calls Nagarwala “an independent physician” who “is not employed by Garden City Hospital.” The hospital characterizes the federal prosecution as a case that was “dismissed by the courts.” It declines to say whether it was aware of Nagarwala’s prosecution when she was credentialed.

Nagarwala, contacted directly, responds: “This is the first I have heard about this.” She does not respond to a follow-up invitation for a full interview.

April 14, 2026 — LARA renews Nagarwala’s license in seven minutes.

Nagarwala submits her renewal application at 12:53 PM. By 1:00 PM, the system emails her a confirmation. The FOIA production contains only what Nagarwala submitted and the automated system emails. No complaint history check. No compliance screening. No human review. No reference to the federal case or the cutting allegations anywhere in the renewal record.

The renewal form’s good moral character questions ask only about convictions, not charges, indictments, arrests, or investigations. Since the federal case was dismissed on constitutional grounds, Nagarwala was not required to disclose her history with the federal FGM prosecution or the cutting allegations.

Her license is renewed through June 19, 2029.

May 18, 2026 — Both agencies deny appeals to release the closure memos on the same day, using the same language.

LARA and the Attorney General’s office each deny FOIA appeals seeking the unredacted closure memos. LARA’s denial, signed by Appeals Officer Adam Sandoval, does not address the argument that the statute requires separating privileged legal analysis from releasable factual content. The AG’s denial, signed by Division Chief Eric Jamison, does not address it either. Neither addresses privilege waiver. Neither addresses the AG’s mixed investigative role.

Both responses contain the same construction. Sandoval refers to the filing as one “which has been characterized as an ‘appeal.’” Jamison refers to the filing as one “which you identify as an ‘appeal.’” Both place the word appeal in scare quotes. Both issued the same day.

The closure memos remain sealed.

June 1, 2026 — The Federation of State Medical Boards declines to condemn licensing physicians who perform genital cutting on children.

The Federation of State Medical Boards (FSMB), the national organization representing every state medical board in the country, is asked whether physicians who performed genital cutting on children should retain active medical licenses.

It responds that it “does not license or discipline individual physicians and is not involved in any decisions about investigations or cases” and “cannot comment on the circumstances involving any particular physician.”

Several of the questions concern FSMB’s own policy positions, not specific physicians. A follow-up removes all case-specific questions and asks only about policy. The FSMB does not respond.

June 6, 2026 — The American Medical Association condemns FGM but defers to the organization that won’t.

The AMA is sent seven questions about the licensing of the Michigan physicians. R.J. Mills of AMA Media & Editorial responds the next day. He answers none of the seven questions.

He calls FGM “child abuse by any physician in the United States” but says the AMA “does not have an authorized role in the regulatory process run by the State of Michigan.”

He refers the inquiry to the Federation of State Medical Boards as “the national voice of the state-run regulatory system for medicine.” Five days earlier, the FSMB declined to condemn genital cutting on children and refused to comment on the case.

June 7, 2026 — No medical organization will say FGM doctors should lose their licenses.

Eleven medical organizations are contacted and asked whether physicians who perform genital cutting on children should retain medical licenses, including the American College of Physicians, the American Academy of Pediatrics, the American College of Obstetricians and Gynecologists, and the American College of Emergency Physicians.

The three that do — the FSMB, the AMA, and the Oakland County Medical Society — do not answer the question. None of the eleven says that female genital cutting on children should cost a physician their medical license.

June 19, 2026 — The lead author of the retracted AAP policy says it should never have been retracted.

Dena S. Davis, the lead author of the AAP’s 2010 ritual nick policy, states in an email that she opposes the retraction. “No, I did not think AAP should have retracted the policy statement,” Davis writes. “Still don’t.”

She adds that "the ritual nick is a good way to equalize male and female, but it would be even better, in my opinion, not to do it at all." Asked to clarify what she means by "equalize," she does not answer.

June 23, 2026 — The AAP does not answer questions about its physicians’ licensing.

Asked five questions about the retraction, Davis’s position, and the licensing of the Michigan physicians, the AAP answers none of them.

It sends its 2020 clinical report on FGM/C. The report does not mention Nagarwala, does not mention Attar, does not mention their continued licensing, and does not mention the absence of disciplinary action.

Asked directly whether the AAP believes physicians who performed FGM/C on children should lose their medical license, the AAP does not reply.

Douglas Diekema, who chaired the committee that published the 2010 policy and is listed as Committee on Bioethics liaison on the 2020 report, does not respond.

Never — A single instance of mandatory reporting.

Every state in the country requires physicians to report suspected child abuse. Physicians are mandatory reporters in Michigan under MCL 722.623, in Minnesota under Minn. Stat. § 626.556, in Illinois under 325 ILCS 5/4 — in all fifty states. The standard is not certainty. It is reasonable cause to suspect. Failure to report is a crime. In Michigan, it is a misdemeanor punishable by up to 93 days in jail.

Federal prosecutors estimated that as many as 100 girls were cut at Attar’s clinic over twelve years. The FBI identified nine victims between the ages of seven and thirteen from three states. One girl told agents she “got a shot” that “hurt really badly and she screamed.” After the procedure, she could barely walk and felt pain all the way down to her ankle. Her parents told her the procedure was “a secret” and that she was not supposed to talk about it. Those girls had other doctors in at least three states. If any of their physicians suspected or saw evidence of what had been done to them and did not report it, that physician committed a crime.

The Government Accountability Office reviewed federal efforts on FGM in 2016. It identified only a handful of U.S. investigations or prosecutions. It noted that healthcare providers may be mandatory reporters. It did not identify a single case that began with a physician’s report. Arkansas, one of the few states that formally tracks FGM reports by healthcare practitioners to its child abuse hotline, reported zero such reports for state fiscal year 2024.

Now — FGM doctors are a part of American medicine.

Michigan has never held a hearing on either physician’s license. The memos that would explain why remain withheld in full under attorney-client privilege. Both physicians practice together at a clinic that advertises school physicals for children and accepts Medicaid. One of those licenses was renewed in seven minutes.

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Next — What could happen.

Before this investigation, the public had no access to the record. Through this investigation that has begun to change. No institution documented above has been required to answer for what these records show.

• The Michigan legislature could hold oversight hearings. The House Oversight Committee has subpoena power over LARA. The officials who closed these investigations, told the press the cases were active months after their own records show they were closed, and dismissed a physician’s complaint by citing a file with no investigative authority can be compelled to testify under oath. No hearing has been held. The committee is chaired by Rep. Jay DeBoyer.

• The Governor could act. LARA is an executive agency. It reports to the Governor. Every closure, every non-investigation, every lie to the press documented above happened within an agency the Governor directs. No Governor has addressed it. The Governor of Michigan is Gretchen Whitmer.

• Federal agencies could review Medicaid provider enrollment. The clinic lists at least seven taxpayer-funded insurance programs. The Centers for Medicare and Medicaid Services has the authority to review whether physicians with documented FGM allegations should remain enrolled as Medicaid and Medicare providers. That review does not require a state disciplinary action that has never come, and it does not require LARA’s cooperation. The Secretary of Health and Human Services is Robert F. Kennedy Jr.

• Courts could unseal the closure memos. The memos explaining why the Attorney General recommended closing both investigations — the only documents that would reveal the state’s reasoning — are withheld in full under attorney-client privilege. Lawyers I have spoken to have told me a legal challenge to those privilege claims would require a $10,000 retainer. The FOIA litigation and investigative reporting behind this article are funded here.

• Victims could bring civil claims. The FBI identified nine victims between the ages of seven and thirteen from three states. Federal prosecutors estimated as many as a hundred girls were cut at the clinic over twelve years. No civil lawsuit has been filed. The statute of limitations for minors in Michigan does not begin to run until they turn eighteen.

• Other states could investigate. The victims came from Michigan, Minnesota, and Illinois. Each state has its own medical board and its own mandatory reporting laws. Whether physicians in those states who treated the girls saw evidence and failed to report it is a question no one has asked.

• Hospitals and insurers could act on their own. Every hospital that grants privileges and every insurer that contracts with these physicians has the independent authority to review that decision. They do not need LARA’s permission.

• Michigan media could cover the licensing story they missed. Local outlets covered the federal arrests in 2017 and the constitutional ruling in 2018. The licensing failure — documented in state records obtained through FOIA — has not been covered. The Detroit Free Press, Bridge Michigan, the Detroit News, WDIV, and CBS Detroit all accept news tips.

• National media could publish what’s already assembled. I assembled this timeline as a single independent journalist. The national press has not touched the case since the federal prosecution collapsed. I’ve already done the bulk of the work for them. The documentation is linked, sourced, and public. Fox News, ProPublica, NBC News, and the Washington Post accept tips.

• International media could cover it through a different lens. International outlets do not share the same cultural and political issues that America has around genital cutting. They have no reason to avoid stories that document American institutional failure. In India, where the Dawoodi Bohra community at the center of this case is headquartered, journalists have covered this story for years. The BBC, Channel 4, and Sky News; the Times of India, The Wire, NDTV, The Caravan, and Al Jazeera all accept tips.

• The story could spread through social media. Every media outlet listed above requires an editor to say yes. Social media does not. Media covers stories that are already trending. One way that could happen is if you share this article.

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• Nothing happens. Every institution and organization documented above failed to act. It is possible that either this investigation doesn’t reach those who can act or they do not act when they read it.

• The unexpected happens. Something not on this list that no one predicted could happen. It depends who reads this and takes action.

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Conclusion

Every failure documented above traces back to the issue that American law forbids genital cutting on girls and permits it on boys. As long as that disparity exists, no institution will be able to confront what happened in Michigan without confronting what happens in every hospital across the country. Holding physicians accountable for female genital cutting will require creating the systems necessary to end male genital cutting. Rather than confront that, they have chosen to permit female genital cutting through non-enforcement.

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Dena S. Davis, the lead author of the American Academy of Pediatrics’ (AAP) retracted 2010 ‘ritual nick’ policy on female genital cutting, told me in an email on June 19, 2026 that she does not believe the AAP should have retracted it.

“No, I did not think AAP should have retracted the policy statement,” Davis wrote. “Still don’t.”

The 2010 policy recommended that physicians be permitted to perform a “ritual nick” on girls’ genitals. The AAP retracted the recommendation within weeks after public outcry. What has not been reported until now is that the lead author who wrote the policy never changed her mind. Davis stands behind the recommendation sixteen years later.

In 2001, Davis published “Male and Female Genital Alteration: A Collision Course with the Law?” in Health Matrix at Case Western Reserve. She argued that the federal law criminalizing all genital alteration on female minors was constitutionally vulnerable because it banned procedures on girls “no matter how minimal the surgery or how safe and sanitary the procedure,” while leaving male circumcision untouched. Once female genital alteration was understood to include a hygienic “ritual nick,” Davis wrote, the two practices “lack a legally defensible distinction.”

The article called out the double standard directly: “What this boils down to is, if you are an American Jew, you can have your baby boy genitally altered with impunity, even if it is done outside a hospital by an unlicensed ritual practitioner, and without the analgesia deemed ‘essential’ by the AAP. But if you are recent immigrant from Somalia, even if you would take the enlightened route and subject your daughter to a ritual nick at the Seattle clinic, you (and the doctor) would be subject to criminal prosecution. This is unacceptable on First Amendment grounds.”

Her recommendation: “Federal and state laws should be rewritten to allow the sort of minor genital nick.”

Nine years later, the AAP’s Committee on Bioethics adopted that position. The committee, chaired by Douglas Diekema of Seattle Children’s Hospital, published a policy statement concluding that “the ritual nick suggested by some pediatricians is not physically harmful and is much less extensive than routine newborn male genital cutting.” The statement lists Davis as “Consultant” with an asterisk denoting her as lead author and cites her 2001 law review article.

The statement suggested that the AAP “opposes all forms of FGC that pose risks of physical or psychological harm” but that “pricking or incising the clitoral skin… is no more of an alteration than ear piercing.” The conditional phrasing — “that pose risks” — created space for forms of genital cutting the committee judged not to pose such risks.

Anti-FGM organizations condemned the recommendation. Equality Now Executive Director Taina Bien-Aimé told The Lancet the statement “defies decades of extremely hard work” to eradicate female genital mutilation. On May 22, 2010, twenty-six days after publication, the AAP’s Board of Directors voted to retire the policy. In a new statement published in July, the AAP wrote: “The AAP does not endorse the practice of offering a ‘clitoral nick.’ This minimal pinprick is forbidden under federal law and the AAP does not recommend it to its members.”

In April 2017, the FBI charged Dr. Jumana Nagarwala in the first federal prosecution under the United States’ female genital mutilation statute. Dr. Fakhruddin Attar, who owned the Livonia, Michigan clinic where the procedures were performed, was also charged.

At Nagarwala’s detention hearing, defense counsel Shannon Smith described the procedures in terms that tracked the AAP committee’s own language. Smith told the court the procedure involved removing a small amount of mucus from the clitoral area — “the amount of a sesame seed” — placed on gauze and given to the family. “It was completely a religious practice,” Smith said.

The defense described the procedures in terms that tracked the AAP committee’s own language. At a detention hearing, defense counsel told the court the procedure involved removing a small amount of mucus from the clitoral area — “the amount of a sesame seed” — placed on gauze and given to the family. “It was completely a religious practice,” the attorney said.

In the criminal complaint, a seven-year-old said Nagarwala took off her pants and underwear and put her on the table. She “got a shot” that “hurt really badly and she screamed.” She drew a picture of the room with an “X” to mark blood on the examining table. Her parents told her “the procedure is a secret and that she is not supposed to talk about it.” Afterward, she could barely walk and felt pain all the way down to her ankle. Nagarwala told her she was fine.

In November 2018, Judge Bernard Friedman of the Eastern District of Michigan dismissed the charges. He struck down the federal FGM statute as exceeding Congress’s authority under the Commerce Clause. The court did not reach the equal protection question of whether banning genital cutting on girls while permitting it on boys constituted sex-based discrimination. The court avoided resolving the constitutional collision Davis described in 2001.

As previously reported, both Nagarwala and Attar hold active, unrestricted Michigan medical licenses with no record of discipline. The state opened investigations into both physicians and closed them without action.

In an exchange over multiple emails between June 18 and June 19, Davis told me she believes “the ritual nick is a good way to equalize male and female, but it would be even better, in my opinion, not to do it at all.”

I asked her to clarify what she meant by “equalize.” She did not answer.

I contacted the AAP on June 21 with five questions: on what basis the statement was retracted, whether the committee was consulted, whether any committee member has said the recommendation was an error, the AAP’s position on the Nagarwala prosecution and its licensing outcome, and whether the AAP has a response to its own lead author’s statement that it would be better if genital cutting were not performed.

Alex Hulvalchick, a media relations specialist in the AAP’s Advocacy and External Affairs division, responded. She did not answer any of those questions. Instead, she sent the AAP’s 2020 clinical report on “Diagnosis, Management, and Treatment of Female Genital Mutilation or Cutting in Girls.”

The 2020 report takes a stronger stance against female genital cutting. It classifies “nicking” as type IV FGM/C and says health care providers “should not perform any type of FGM/C” on girls. This report rejects the harm-reduction argument behind the ritual nick proposal, stating that “By agreeing to perform the procedure, however, health care providers are granting it medical legitimacy, which not only undercuts the moral prohibition on the procedure but also contributes to its spread and ongoing societal acceptance.”

The report directly acknowledges the Nagarwala prosecution but treats it as a constitutional ruling. It does not mention Attar, does not mention their continued licensing, and does not mention the absence of any disciplinary action. It was reaffirmed in January 2026.

I replied to the AAP: “The report does not address my five questions about the 2010 policy statement, its retraction, or Dr. Davis’s position. It also does not address my May 27 inquiry about the licensing of the Michigan physicians. I still need responses to both.” I asked directly, based on the report the AAP itself sent me: “Does the AAP believe physicians who performed FGM/C on children should lose their medical license?”

They did not reply.

Diekema is listed as Committee on Bioethics liaison on the 2020 report. He chaired the committee that recommended the ritual nick in 2010. I contacted Diekema separately with five questions, including whether he agreed with Davis that the retraction was wrong.

He did not respond.

The federal FGM statute that was struck down in the Nagarwala case has been replaced by the STOP FGM Act of 2020. Hadachek v. Oregon, filed in state circuit court in March 2025, argues that Oregon's FGM statute violates equal protection by protecting only girls from non-therapeutic genital cutting.

Davis wrote the argument in 2001. The AAP adopted it in 2010 and retracted it twenty-six days later. The author who wrote it still says the AAP should never have retracted it. No medical organization, insurer, or licensing board has said that physicians prosecuted for FGM should lose their licenses.

“No, I did not think AAP should have retracted the policy statement--still don’t. Good luck with publishing.”

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A federal prosecutor told Michigan's licensing investigator that a medical witness in the state's investigation would not be providing a statement. The state never interviewed another witness in the case.

The witness was Dr. Dena Nazer, a board-certified child abuse pediatrician at Kids TALK Medical Center. Nazer is a professor of pediatrics at Wayne State University School of Medicine and currently serves as chair of the Michigan Human Trafficking Health Advisory Board, appointed by the governor. Her job is evaluating children suspected of being maltreated.

Michigan’s licensing agency wanted to talk to her. The federal government said no.

On September 27, 2017, Michigan Department of Licensing and Regulatory Affairs (LARA) investigator Jennifer Pappas left a message for Nazer at Kids TALK. The interview had been requested by the Michigan Attorney General’s office itself. Pappas’s investigation report states that “an Additional Investigation was requested from the Assistant Attorney General’s Office requesting this Investigator interview WITNESS NAZER.”

The next day, Nazer called back and left a message. That afternoon, Pappas reached Nazer by phone and requested an interview. She also emailed a formal witness letter. Nazer responded that she would forward the request to her attorneys.

On September 29, 2017, at 1:35 PM, U.S. Assistant Attorney Sara Woodward, the lead federal prosecutor on the FGM case, called Pappas. Woodward told Pappas that Nazer “will not be providing a statement to our Bureau due to the pending Federal Court Case and due to WITNESS NAZER’s limited knowledge about the licensee’s activities.”

The federal prosecutor called the state investigator and told her the witness was off limits.

When contacted for this article, Nazer said she was “always willing to cooperate with the state licensing investigation.” She did not address whether the federal prosecutor directed her not to provide a statement. She said “the investigation was still ongoing, and I did not have direct knowledge about Nagarwala’s actions” — language matching Woodward’s stated rationale but attributed to herself.

Nazer also said she “had contact with the office” in 2019 “for updates,” after the investigation had closed. She did not specify which office. She said she remains willing to share her perspective with the state licensing investigation.

Pappas submitted her investigation report to her supervisor on September 29, 2017. The report lists two attachments: the witness letter she sent to Nazer and the email Nazer sent back. It does not document any further investigative activity.

The Michigan Board of Medicine had authorized the investigation on April 18, 2017, after Nagarwala’s arrest. The state closed the investigation on September 25, 2018, with no action taken, nearly two months before the federal court ruling. The memo explaining why is fully redacted.

Nagarwala’s medical license (No. 4301071795) remains active and unrestricted. Michigan renewed it through 2029 while this reporting was underway. She and Dr. Fakhruddin Attar have since opened a new clinic together in Detroit, where they advertise school physicals for children.

This sequence is documented in LARA’s own Investigation Report for complaint file 43-XX-146153, authored by Pappas. The report was obtained through a Freedom of Information Act request to the Michigan Attorney General’s office.

LARA did not release this report. In January 2026, I filed a FOIA request to LARA for “all records relating to Dr. Jumana Nagarwala, including investigative files.” LARA produced the complaint file with redactions but did not include the Pappas investigation report. The report was authored by LARA’s own investigator, about LARA’s own complaint file, and submitted to LARA’s own supervisor. It was obtained only because the Attorney General’s office had a copy in its files and released it. LARA has previously lied to the press about its investigations.

Sara Woodward, who is no longer at the U.S. Attorney’s Office and now works as a Trial Attorney in the Health Care Fraud Unit at the Department of Justice in Washington, responded but did not answer questions about her actions. She redirected the inquiry to the current U.S. Attorney’s Office. When informed the questions concerned her personal actions, she did not respond further.

LARA, the Michigan Attorney General’s office, and the U.S. Attorney’s Office for the Eastern District of Michigan did not respond to requests for comment.

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This is an ongoing investigation. If you’d like to support this work, you can contribute here: Expose Medical Board for Licensing an FGM Doctor.

Taxpayer-funded insurance programs pay two physicians federally prosecuted for performing genital cutting on children. No insurer or government agency will say whether it has ever reviewed them.

Dr. Jumana Nagarwala and Dr. Fakhruddin Attar were charged in the first federal prosecution of female genital mutilation in United States history. Both hold active, unrestricted Michigan medical licenses after the state closed its investigations without discipline. As previously reported, they now practice together at Livernois Primary and Urgent Care in Detroit, a clinic Nagarwala founded. The clinic’s website lists 13 accepted insurers. Seven are taxpayer-funded programs.

On June 15, I sent comment requests to Blue Cross Blue Shield of Michigan, Aetna Better Health of Michigan, Priority Health, UnitedHealthcare, Molina Healthcare of Michigan, HAP, Meridian Health Plan and Ambetter (both operated by Centene), McLaren Health Plan, Humana, the Michigan Department of Health and Human Services, and the Centers for Medicare and Medicaid Services. Each received a set of questions about physicians federally prosecuted for genital cutting on children with a request to respond by June 18.

Three responded. None named either physician. None answered the questions.

Blue Cross Blue Shield of Michigan (BCBSM) issued a statement attributable to the company:

“Blue Cross Blue Shield of Michigan is committed to providing our members with access to high quality healthcare providers. Part of our role is to protect our members from the human and financial costs of waste, fraud, and abuse. Should we determine that a crime has been potentially committed by a provider in our network, we have a dedicated investigations team that works with law enforcement to bring that provider to justice.”

BCBSM did not confirm or deny whether Nagarwala or Attar are in its network. It did not say whether it had reviewed either physician.

Aetna Better Health of Michigan, a Medicaid managed care plan, responded through Phillip Blando:

“Aetna Better Health of Michigan complies with all federal and state rules and regulations. Health care providers serving Medicaid beneficiaries in Michigan are screened through the State’s provider enrollment system. In addition, providers that are suspended or removed from the system, or subject to state or federal payment suspensions are not reimbursed by the state’s Medicaid program.”

Aetna did not name either physician. It deferred responsibility to the state’s provider enrollment system.

The Michigan Department of Health and Human Services, which administers Medicaid in Michigan, responded through spokesperson Lynn Sutfin:

“MDHHS is committed to ensuring that Michigan families have access to affordable health care and that every Medicaid provider is properly licensed and meets all state and federal requirements.”

MDHHS did not name either physician. It did not answer any of the five specific questions it received, including whether it was aware that Nagarwala and Attar are Medicaid-eligible providers, whether it had reviewed the federal prosecution, or whether it had any concerns about these physicians treating Medicaid beneficiaries, including children.

The following did not respond:

• Priority Health.

• United Healthcare.

• Molina Healthcare of Michigan.

• HAP (Health Alliance Plan).

• Meridian Health Plan and Ambetter, both operated by Centene

• McLaren Health Plan.

• Humana.

• The Centers for Medicare and Medicaid Services.

All of the above insurers are listed on the website for Livernois clinic owned by Nagarwala here.

Aetna says Medicaid providers are screened through the state’s enrollment system. MDHHS says it ensures providers are properly licensed. The licensing agency, Michigan’s Department of Licensing and Regulatory Affairs, closed its investigations into both physicians without discipline. LARA’s Board of Medicine unanimously recommended summary suspension in April 2017. Neither license was ever suspended. Both investigations were closed before the federal case ended.

The insurer relies on the state enrollment system. The state enrollment system relies on the licensing system. The licensing system closed the case.

No institution in this chain said it had reviewed whether these physicians should be in its network.

Female genital cutting on children is a federal crime under the STOP FGM Act of 2020 and is illegal in most states, including Michigan.

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Two state agencies denied appeals to release the memo that closed Michigan’s only licensing investigation of a doctor federally indicted for performing female genital mutilation on children. They issued their denials on the same day. They used the same language.

The document at issue is a July 27, 2018 memorandum authored by Assistant Attorney General Bridget K. Smith, titled “Request to Close File.” It recommended that the Bureau of Professional Licensing end its investigation of Dr. Jumana Nagarwala without disciplinary action. A redacted version exists in the state’s files. Every word of substance has been blacked out.

As previously reported, the investigation closed on September 25, 2018, two months before the federal prosecution was dismissed. No licensing discipline resulted. Dr. Nagarwala holds an active, unrestricted Michigan medical license. LARA renewed it through June 2029 this past April, in seven minutes, with no screening of her complaint history. Dr. Fakhruddin Attar, the clinic owner charged alongside her, also holds an active, unrestricted license through March 2027. His clinic has reopened at a new location in Farmington Hills. Both physicians now also practice together at Livernois Primary and Urgent Care in Detroit.

The closure memo is the only document that explains why.

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On May 1, 2026, I appealed to LARA, the licensing agency that received the memo and closed the investigation. The appeal argued that Michigan’s FOIA statute requires agencies to separate privileged legal analysis from factual content and release the non-privileged portions. It cited the AG’s own privilege log, which revealed two versions of the memo sent to two different bureau directors, neither previously disclosed by LARA.

On May 2, I filed a parallel appeal to the Attorney General, the agency whose lawyer wrote it. That appeal made four arguments: that the statute requires segregation of exempt and non-exempt material, that the AG’s role in this case was investigative rather than purely advisory, that factual content is not automatically privileged because an attorney wrote it, and that privilege may have been waived through disclosures to federal prosecutors.

Both agencies denied the appeals on May 18, 2026.

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LARA’s denial, signed by Appeals Officer Adam Sandoval, did not address the segregation argument. It did not address the two-version discrepancy. It did not address LARA’s independent authority to waive privilege as the client. It offered one paragraph of analysis: the memo “fall[s] squarely within this privilege, and redactions made were appropriate.”

The AG’s denial, signed by Division Chief Eric Jamison of the State Operations Division, did not address the segregation argument. It did not address the waiver question. It did not address the AG’s mixed investigative role. It accused the requester of having “neglected to mention” that privilege covers an attorney’s factual materials.

My appeal had stated: “Even if portions of the memorandum contain privileged legal analysis, the AG has not justified withholding the document in its entirety.” This statement directly addresses the point their denial claims I “neglected to mention.”

Both denials share a distinctive feature. Sandoval’s response refers to the filing as one “which has been characterized as an ‘appeal.’” Jamison’s response refers to the filing as one “which you identify as an ‘appeal.’” Both place the word appeal in quotation marks. Both use distancing language to suggest the filings were not, in their view, actually appeals.

This is the same rhetorical construction, scare quotes around the same word, applied through the same syntactic structure, appearing in official legal determinations from two different agencies, signed by two different officials, on the same day.

The AG’s Licensing and Regulation Division is the common thread. AAG Smith authored the closure memo. Her division would have been consulted before LARA could rule on whether to release a communication from its own attorney. The parallel language in the denials is consistent with both responses having been shaped by the same legal position, if not the same drafter.

However, the scare quotes and editorializing in the response raised a question: Was what I sent them an appeal or merely “characterized” as an appeal? Because, if it was not an appeal, I still had a legal right to file one.

On May 24, I asked both agencies whether their May 18 responses constituted final determinations under MCL 15.240. I asked why the responses used language distinguishing the filings from appeals, and whether I was entitled to file one.

LARA’s FOIA Office responded on May 26 and confirmed the filing was an appeal and their response a final determination and I could not file another appeal. They did not explain why Sandoval’s written denial characterized that same filing as something other than an appeal when LARA says it treated it as one.

The Attorney General did not respond. I sent a follow-up on June 6. The AG did not respond to that either. Since the AG would not confirm whether they considered my first appeal an actual appeal or its May 18 response was a final determination, I filed a second appeal on June 8.

My second appeal restated the four original arguments, documented that the AG’s May 18 response had not addressed any of them, and proved that the “neglected to mention” claim was wrong by quoting the passage from the first appeal that directly argued the point. It asked the AG to address each argument individually, to identify any arguments it was declining to address, and to explicitly state whether its response constituted a final determination.

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On June 12, the AG responded. The response is seven pages. It is signed by FOIA Coordinator Christy Wendling-Richards, not by Division Chief Jamison, who signed the May 18 denial.

The first five pages reproduce the text of the June 8 appeal. Page six reproduces the May 18 Jamison denial, word for word. Page seven adds a referral to the Michigan State Bar’s lawyer referral service, where a $25 fee will connect the requester with an attorney for a 25-minute consultation.

The AG did not address the segregation argument. It did not address the mixed investigative role argument. It did not address the privilege waiver argument. It did not address the request for particularized justification. It did not identify which arguments it was declining to address. It did not state whether the response was a final determination.

The letter does contain one structural change. The May 18 denial referred to “your May 2, 2026 email, which you identify as an ‘appeal.’” The June 12 response refers to “your May 2, 2026 appeal.” The scare quotes are gone. The AG now calls it an appeal, while reproducing a denial that treated it as something less than one.

The June 12 letter also contains a particular arrangement. Pages two through five include the passage from the second appeal proving that the first appeal argued the very point the AG claimed it “neglected to mention.” Page six reproduces the “neglected to mention” claim. The AG placed the refutation and the claim it refutes in the same document, in sequence, and issued both as its official position.

The closure memo remains sealed. The public has no way to know why the state continues to license physicians federally prosecuted for FGM and their response to attempts to disclose their reasoning indicate they will not address arguments for disclosure unless a court compels them to.

A Court of Claims lawsuit could unseal the memo. If you’d like to support legal action, contribute here: Expose Medical Board for Licensing an FGM Doctor

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The two physicians at the center of America’s first federal FGM prosecution have opened an urgent care clinic together in Detroit where they are advertising school physicals for children.

Dr. Jumana Nagarwala and Dr. Fakhruddin Attar are listed as providers at Livernois Primary and Urgent Care, a clinic at 18254 Livernois in Detroit’s University District neighborhood. Nagarwala is listed as the clinic’s founder. Attar is listed as staff. Both hold active, unrestricted Michigan medical licenses with no public record of discipline.

The last time Nagarwala and Attar worked out of the same clinic was Burhani Medical Clinic in Livonia — the location where, according to the federal indictment in United States v. Nagarwala (2:17-cr-20274, E.D. Mich.), Nagarwala performed FGM procedures on minor girls while Attar opened his clinic after hours to let her do it.

Now they’ve rebuilt together in a clinic Nagarwala founded herself.

The practice registered its National Provider Identifier (NPI 1659021509) on March 24, 2022. The current website launched in spring 2025, with staff photos uploaded in April and May of that year. As of June 15, 2026, the clinic’s Google listing shows 131 reviews and a 4.8-star rating. The business identifies itself on Google as “women-owned,” “Asian-owned,” and “LGBTQ+ friendly.”

The clinic’s services page lists general illness and injury care, occupational health screenings, labs, x-rays, flu shots, and physical exams. The physical exams page specifically advertises “school physicals,” “sports physicals,” “camp and program physicals,” and “childhood and adult immunizations,” services marketed to children and their parents.

The clinic accepts 13 insurance providers, at least seven of which are taxpayer-funded: Medicaid of Michigan, Medicare of Michigan, UnitedHealthcare Community Plan, Molina Healthcare, Meridian Health Plan, Aetna Better Health of Michigan, and McLaren Medicaid. (I have reached out to all for comment and will update once they respond.)

Nagarwala’s bio on the clinic’s website describes her as “a board-certified emergency medicine physician with over 20 years of clinical and academic experience” and a graduate of Johns Hopkins School of Medicine. It mentions senior roles at Henry Ford Hospital. It does not mention the federal prosecution.

Attar’s bio describes him as “a board-certified Internal Medicine physician who has been practicing for over 25 years,” with residency training at Albert Einstein College of Medicine. It does not mention the federal prosecution.

A third provider, listed only as “Mr. Ayyub,” is described as a certified physician assistant with a master’s from Western Michigan University and 13 years of experience on the Acute and Critical Care Team at Corewell Health in Royal Oak. A Tebra listing identifies him as Ayyub Ahmad (NPI 1861708711). Physician assistants in Michigan practice under physician supervision, in this case, under Nagarwala or Attar.

In 2017, federal prosecutors alleged that Nagarwala performed FGM on at least nine minor victims at Burhani Medical Clinic, Attar’s clinic, between 2015 and 2017. The indictment alleged that Attar opened his clinic after hours to allow the procedures, and that both physicians instructed others not to speak about what had taken place. Families traveled from as far as Minnesota to bring their daughters to the clinic.

The federal case was dismissed in 2018 after the trial judge ruled the federal FGM statute unconstitutional. Michigan’s Department of Licensing and Regulatory Affairs opened complaint investigations into both physicians and closed them without disciplinary action, before the federal case concluded. Both physicians retained their licenses throughout. Nagarwala renewed hers through June 19, 2029, despite complaints.

Now they are seeing patients together again, at a clinic that advertises school physicals for children, accepts Medicaid, and identifies itself as “women-owned” and “LGBTQ+ friendly” on Google.

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This is an ongoing investigation. If you’d like to support this work, you can contribute here: Expose Medical Board for Licensing an FGM Doctor.

Michigan renewed the medical license of Dr. Jumana Nagarwala, the physician charged in America’s first federal FGM prosecution, through 2029 in seven minutes, with no human review, no screening of her complaint history, and no reference to the federal case or the cutting allegations anywhere in the renewal record.

Records obtained through the Freedom of Information Act show that Nagarwala submitted her renewal application on April 14, 2026 at 12:53 PM. By 1:00 PM, the system had emailed her a confirmation.

The production contained only what Nagarwala submitted and the automated system emails. Nothing in the record indicates anyone at the Michigan Department of Licensing and Regulatory Affairs (LARA) looked at Nagarwala’s file before extending her license by three years.

Her license number (4301071795) now shows an expiration date of June 19, 2029 in the state’s public licensing database. When this publication first reported on Nagarwala’s license status in January 2026, the same database showed an expiration of June 19, 2026. Her previous medical license is archived here and the new medical license is archived here.

LARA has at least four complaint files on this physician:

• The original civil investigation (43-XX-146153), which the agency closed in September 2018 with the disposition “No Action Taken” two months before the federal charges were even dismissed.

• The criminal monitoring file (146169), opened to track the federal prosecution.

• A 2019 complaint from a physician who called Nagarwala’s practice of genital cutting on children without anesthesia “torture,” which LARA dismissed by citing the monitoring file rather than the closed investigation.

• A 2025 patient complaint filed against Nagarwala by a patient she treated at GCH Westland Emergency Room.

LARA renewed Nagarwala’s license anyway.

The renewal application asks two good moral character questions. Both ask only about convictions not previously reported to the department. Since the federal case against Nagarwala was dismissed on constitutional grounds, Nagarwala was not required to disclose her history with FGM or the previous federal case against her.

The form does not ask about criminal charges, indictments, arrests, or investigations, open or closed, by this department. The sanctions question asks only whether another state or country has imposed sanctions. Michigan’s own history with the licensee is structurally invisible on its own renewal form.

A patient complaint filed in 2025 alleged Nagarwala improperly administered a drug injection at GCH Westland Emergency Room. Her controlled substance license was also renewed.

The renewal took place during a period when LARA’s own communications director had personally responded to this publication’s questions about whether the agency made false statements to Medscape about the status of the investigations, breaking a months-long pattern of silence across multiple published articles. The agency’s Director of Legal Affairs had been CC’d on correspondence from a Board of Medicine reviewer who treated the inquiry as a legal exposure question. FOIA requests targeting internal communications about the case were active and pending response.

None of that stopped the renewal.

Nagarwala was charged in April 2017 with performing genital cutting on young girls at a Livonia clinic, in what federal prosecutors called the first FGM case in U.S. history. The FBI identified nine victims between the ages of seven and thirteen from Michigan, Minnesota, and Illinois. Prosecutors estimated as many as 100 girls may have been cut over a twelve-year period. The federal case ended in November 2018 after U.S. District Judge Bernard Friedman ruled the federal FGM statute unconstitutional. No party in the case disputed that the procedures occurred.

Michigan’s Board of Medicine authorized an investigation days after the federal arrest. Internal emails show LARA staff requested a summary suspension and administrative complaint. Neither was executed. Michigan never held hearings on her license. The state closed its investigation with “No Action Taken,” and the closure memo, authored by Assistant Attorney General Bridget K. Smith and addressed to then-Bureau of Professional Licensing Director Cheryl Wykoff Pezon, remains withheld in full under attorney-client privilege.

Dr. Fakhruddin Attar, who owned the Livonia clinic where prosecutors alleged the procedures took place, also holds an active, unrestricted medical license (No. 4301067384). His clinic is still open and his license does not expire until March 2027. As previously reported, LARA never assigned an investigator to his case and certified that “a traditional investigation was not conducted.”

No medical organization contacted for this investigation was willing to say that a physician who performed genital cutting on children should lose their medical license.

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This is an ongoing investigation. If you’d like to support this work, you can contribute here: Expose Medical Board for Licensing an FGM Doctor.

State licensing records obtained through a Freedom of Information Act request show the complaint was filed on May 17, 2025, through Michigan’s MiPLUS system. The patient reported that Nagarwala administered a 30-milligram ketorolac injection following a car accident involving a concussion. The incident occurred on April 28, 2025. The complaint lists Nagarwala’s business address as GCH Westland Emergency Room, 6245 Inkster Road, Garden City, MI 48135.

Garden City Hospital, asked to comment, provided a statement through a spokesperson describing Nagarwala as “an independent physician” who “is not employed by Garden City Hospital.” The hospital did not address whether she holds active privileges at the facility.

The statement characterized the federal prosecution as a case that was “dismissed by the courts.” The federal FGM charges were dismissed after the presiding judge ruled the statute unconstitutional, finding that Congress lacked authority under the Commerce Clause to criminalize the practice. The ruling addressed the law, not Nagarwala’s conduct.

The hospital said it maintains “rigorous screening and credentialing processes” including verification of “licensure, background, certifications, training, professional qualifications, and other relevant information,” but declined to say whether it was aware of Nagarwala’s federal prosecution when she was credentialed. Notably absent in their statement was a direct answer to my question “Does Garden City Hospital's credentialing process include an internet search of a physician's name?” or what its position is on credentialing physicians who have been prosecuted for performing genital cutting on children.

“As a matter of policy, Garden City Hospital does not comment on individual credentialing matters or personnel-related issues,” the statement said.

Nagarwala, contacted for comment, initially responded to ask about the identity of the patient who filed the complaint. “This is the first I have heard about this,” she wrote. She has not yet responded to follow-up questions or to an invitation to share her perspective in a recorded longform interview.

The complaint itself appears insignificant. Though Ketorolac risks worsening an undetected intracranial bleed, it is still a common pain medication administered in emergency rooms. What is significant is that a patient walked into a suburban Detroit emergency room, was treated by a doctor who had been charged with performing genital cutting on children, and had no way of knowing.

This is not the first complaint on Dr. Nagarwala’s license. In June 2019, a board-certified anesthesiologist filed a complaint calling Dr. Nagarwala’s cutting of young girls “torture.” LARA dismissed the complaint by claiming they had already conducted an investigation they had not. Now there is a second complaint, filed by a patient who apparently did not know her history at all.

Emergency rooms are not like other medical settings. You do not choose your doctor. You are brought in by ambulance or you walk in from the waiting room, and you see whoever is on shift. Patients rely on the system — the licensing board, the hospital credentialing process, the state — to protect them.

Nothing on Nagarwala’s public license record would make a patient aware of her history, despite there being two complaints on her file. No action has been taken on the complaints against her. No medical organization will say that doctors who perform FGM should not be licensed.

The patient who filed this complaint had no way of knowing who their doctor was. Neither would you.

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This is an ongoing investigation. If you’d like to support this work, you can contribute here: Expose Medical Board for Licensing an FGM Doctor