After a couple was arrested in a child abuse investigation centered on a home in Arcadia where authorities said nearly two dozen children, many born via surrogates, were living, surrogacy experts told NBC Los Angeles that the alleged surrogacy scheme may have been completely legal.
Guojon Xuan, 65, and his wife, Sylvia Zhang, 38, were arrested Tuesday on suspicion of conspiracy to commit child abuse. Authorities said the couple ran their own surrogacy center out of their Arcadia home.
The husband and wife also operated the business that allowed them to hire surrogate mothers from across the United States, according to authorities. Investigators said children born through those surrogacy arrangements had been living in “horrific” conditions.
“California is what we consider the Wild West when it comes to the fertility industry,” said Kallie Fell, executive director of the Center for Bioethics and Culture, adding that the Arcadia case has exposed serious concerns about the lack of regulation in the surrogacy industry, particularly in California.
“They have built a legal framework that makes it really easy to establish contractual parentage through surrogacy,” Fell said.
Surrogacy is a multibillion-dollar global industry that helps countless people have children they may not otherwise be able to carry themselves.
According to surrogacy attorney Stephanie Caballero, the only requirement to open a surrogacy business is obtaining a business license.
“I have a license as an attorney; the physicians have licenses; mental health professionals and social workers have licenses,” Caballero said. “The surrogacy agencies do not have a license.”
There are more than 500 surrogacy agencies in the United States. One of them is Ember Fertility Center in Laguna Hills, which conducts strict screening procedures to ensure prospective parents are a good match for surrogates, according to operations director Annie Zhang.
“Our physicians always evaluate intended parents. For donors and surrogates, psychological reviews by specialists are pretty much required,” Zhang said.
However, Zhang said such screening processes are not required by any regulatory agency.
“What are their daily routines, habits and expectations? It’s very casual,” she said. “But there are certain things that have to be disclosed, such as the source of the egg or sperm, whether it comes from the intended parents or a donor.”
The Arcadia couple was being held in lieu of $20 million bail each pending a bail review hearing Monday.
Police focused on the property after receiving a child abuse allegation in May 2025, when Zhang brought the couple’s 2-month-old son to Children’s Hospital Los Angeles, where doctors found the infant had suffered a brain bleed.
During the investigation, detectives discovered nearly two dozen children, ranging in age from 2 months to 13 years old, living inside the home.
Los Angeles County authorities said the couple began living at the residence in April 2021.