During the 1940s, several cases arose from the provision of contraception by the Waterbury clinic, leading to legal challenges to the constitutionality of the Comstock law, but these failed on technical grounds. In "Tileston v. Ullman" (1943), a doctor and mother challenged the law on the grounds that a ban on contraception could, in certain sexual situations, threaten the lives and well-being of patients. The U.S. Supreme Court dismissed the appeal on the grounds that the plaintiff lacked standing to sue on behalf of his patients. Yale School of Medicine gynecologist C. Lee Buxton and his patients brought a second challenge to the law in "Poe v. Ullman" (1961). The Supreme Court again dismissed the appeal, on the grounds that the case was not "ripe": the plaintiffs had not been charged or threatened with prosecution, so there was no actual controversy for the Court to resolve.