Avoidance of the peritoneal cavity is surgically sound and is a primary defense against infections that complicate cesarean sections. A decade of data confirms previous findings that the extraperitoneal cesarean section is an efficacious surgical procedure. Data from 346 cases during this 10-year period support the recommendation that the procedure is a viable alternative to the transperitoneal cesarean section. My experience suggests that the extraperitoneal approach is being rejected not because it lacks merit but because of other factors.