Two courts have required castration surgically or using Depo-Provera as condition of probation. However, a castration condition is an illegal exercise of a court's statutorily based power of probation, because the castration condition of probation is not reasonably related to the crime of rape. In addition, an effective order would have to forbid castrates from ever taking testosterone or to require them to take Depo-Provera forever. Moreover, the inadequacy of the research data about castration mean that a convicted rapist cannot knowingly and freely accept a castration condition in an offer of probation. A castration condition also violates the defendant's constitutional rights by intruding upon the first amendment right to think about sex and to the privacy of sexual fantasies. Castration is also a cruel and unusual punishment under the eighth amendment. Finally, castration does not respect the due process privacy right. Surgical castration is not the least restrictive means to serve the State's compelling interest in protecting society, and Depo-Provera is not rationally related to the State's legitimate interest in curbing rape. 164 footnotes.