
A wealthy California couple’s operation to produce 22 children through surrogacy while evading all industry safeguards has exposed massive gaps in federal oversight that could enable trafficking disguised as family-building.
Story Snapshot
- Arcadia police discovered 21 children in a mansion owned by Silvia Zhang and Guojun Xuan, who bypassed surrogacy agencies to self-match with paid surrogates
- A two-month-old suffered severe head injuries from nanny abuse captured on 25 surveillance cameras that parents allegedly never reviewed
- FBI launched a federal probe into potential trafficking involving interstate child transport and payments, while nanny Chunmei Li remains a fugitive
- The unprecedented case exposes how America’s lack of federal surrogacy regulation allows exploitation that puts children at risk
Surrogacy Operation Discovered After Infant Abuse
Arcadia police raided a beige stone mansion on May 9, 2025, after Silvia Zhang brought a two-month-old boy with bruises, brain bleeding, and retinal hemorrhaging to Children’s Hospital Los Angeles two days earlier. Officers discovered 15 toddlers aged mostly one to three years, all with identical buzzcuts, living under the care of six live-in nannies. LA County Department of Children and Family Services removed these children plus six others located elsewhere, totaling 21 children. Zhang, 38, and her partner Guojun Xuan, 65, claimed to have 22 children almost entirely produced through paid surrogates, with Zhang giving birth to only one or two herself.
Parents Bypassed Industry Standards to Build Family
Zhang and Xuan circumvented California’s surrogacy framework by self-matching with surrogates rather than using licensed agencies. This unprecedented approach allowed them to avoid the industry’s standard safeguards, including notarized contracts, separate legal representation for surrogates, and clinic oversight of embryo handling. Surrogacy experts told investigators this was the first known instance of intended parents serving as their own matchmakers. The mansion functioned like a school facility monitored by 25 surveillance cameras, yet the couple allegedly never reviewed footage showing nanny Chunmei Li shaking and dropping the injured infant. Both Zhang and Xuan were arrested on child neglect charges but released without formal prosecution as investigations continued.
Criminal Property Ties Deepen Federal Concerns
Xuan’s real estate holdings include a property in El Monte that authorities raided multiple times between 2022 and 2025 for drug-related activities, including marijuana cultivation, psilocybin possession, and illegal gambling operations. This property history raised additional red flags for investigators already examining the couple’s surrogacy arrangements. The FBI joined the investigation to assess potential federal trafficking violations involving interstate transportation of children and financial payments to surrogates. Arcadia Police Lieutenant Kollin Cieadlo stated investigators were not focusing on surrogacy’s legality but rather on child welfare and possible exploitation. The surrogates themselves were reportedly unaware of the total number of children being produced or the family’s overall situation.
Federal Regulatory Void Enabled Exploitation
The United States maintains no federal surrogacy regulations, leaving oversight to individual states with vastly different approaches. California is considered surrogacy-friendly, requiring certain contractual and medical protections, but the Zhang-Xuan case revealed how easily determined actors can evade even these modest safeguards. Surrogacy attorney Wald emphasized that industry checks typically exist through clinics and agencies, making the parents’ role as direct matchers completely outside normal standards. This case has distressed the surrogacy community by demonstrating how the regulatory vacuum can be exploited to create situations that undermine child welfare and potentially facilitate trafficking. The 21 children remain in foster care as of late 2025, with the injured infant reportedly stabilized but the broader investigation still active.
Unanswered Questions About Intent and Accountability
Investigators remain uncertain whether this operation constituted a large family built through unconventional means or something more sinister involving child trafficking or exploitation. The FBI has declined to comment publicly on its probe, while Arcadia police continue focusing on abuse and neglect aspects rather than the surrogacy arrangements themselves. Nanny Chunmei Li remains a fugitive after fleeing following the raid. Neither Zhang nor Xuan has made public statements, and no additional charges have been filed against them beyond the initial neglect arrests. The case has stigmatized Arcadia’s affluent Chinese émigré community and sparked debates about whether large-scale surrogacy operations should trigger automatic scrutiny. Limited data on the couple’s motivations and the surrogates’ full experiences leaves critical questions unanswered about accountability and prevention of similar situations.
Sources:
Why No Federal Rules Regulation for Surrogacy 21 Children Removed – Fortune
Arcadia Surrogacy Case – Los Angeles Times


