Introduction:

This essay is about the Abortion Rights Movement and its relevance in relation to history, law, and health. The whole of this work is centered on the landmark 1973 US Supreme Court decision Roe et al. v Wade.

I. Planted seed

It was the Birth Control Movement that gave life to the Abortion Rights Movement, and it was the Abortion Rights Movement that gave life to Roe v. Wade. Before the Industrial Revolution, there was little ability to protect children from various illnesses that were tragically mortal, and so as insurance couples would have many children, so that way at least some would enter adulthood. When the Industrial Revolution hit, the amount of food and later medical benefits, sanitation, and standard of living, all increased substantially. Most married couples, usually those at the lower classes, continued to have very large families. Many people, such as social worker Margaret Sanger, saw this as hazardous.

Through the eyewitness accounts of women suffering premature death from multiple pregnancies and poverty increased through the large number of mouths to feed, several people began to believe that there should be ways to inhibit continual pregnancies. A popular idea, practiced to this day, was for people to wait to get married and/or wait to have children, thereby decreasing the feasibility that many children would come out of the family. So, out of compassion, (rather than a drive to destroy the family unit) many individuals promoted the idea not just of waiting, but rather using contraceptives to inhibit conception.

Contrary to the popular envisioning of the Birth Control Movement, which eventually added to its agenda the use of abortion to terminate pregnancies, it was not originally supported by any chapter of the Women’s Liberation Movement. Indeed, women closely associated with the movement, such as Alice Paul and Susan B. Anthony, both opposed the practice. Further, it was not just Catholic Priests and Protestant Ministers who were against abortion, but also the medical professionals at the time as well, who were noted as being the primary pressure group politically in both England and the United States regarding abortion.

“The political pressure brought by physicians in the nineteenth century for more effective laws against abortion cannot be adequately explained unless it is understood that they were concerned to protect unborn children as well as to protect women and to uphold their own professional standards.”¹

Writes Whitney,

“In the beginning abortion controls were based not on morality or the alleged rights of the unborn but on concern for the health of the mother.”²

None of these professionals believed that what they were doing was to be done in order to deprive women of their individuality or rights, but to protect them. The countless dangers of what were named ‘back-alley abortions’ are commonly understood by none other than Justice Blackmun, who wrote the majority opinion for the Court in that infamous case Roe v. Wade: “When most criminal abortion laws were first enacted, the procedure was a hazardous one for the woman.”³ As aforementioned, medical professionals fully knowledgeable of the harms involved were the ones who pushed antiabortion laws through legislatures.

Pro-choice advocates do not often mention some of the questionable motives of those involved in the Birth Control Movement, which was the harbinger of the Abortion Rights Movement. I first came across the claim of racism through a left-wing website, commenting critically of a recent radio broadcast of Dr. James Dobson, founder and current head of Focus on the Family. He apparently was speaking of the racist tendencies of many in the early Birth Control Movement, such as Margaret Sanger, and how their intentions included aborting away the black race, amongst others. I dismissed most of this as questionable until I came upon Alexander Sanger, pro-choice advocate and grandson of Margaret Sanger.

The World Book Encyclopedia defines eugenics as “a method that aims at improving the human race by selection of parents based on their inherited characteristics.”⁴ It was developed as a concept in the late nineteenth century and gained its peak of acceptance in the early 20th. Although the idea unto itself is fairly innocent, it has been used in very disturbing ways, and has been accredited with inspiring various disturbing pieces of legislation in numerous countries.⁵ Since the cornerstone of eugenics is selective human breeding, it appeared to be the perfect match for the Birth Control-Abortion Movement. Indeed, Alexander Sanger acknowledges the collaboration between the two entities:

“My grandmother had supported some eugenic goals and this support continues to haunt the pro-choice movement today.”⁶

He goes farther than this, and speaks of the damage of guilt by association:

“I believe the pro-choice movement was scared away from making biological arguments because of the birth control movement’s disastrous foray into eugenics a half century earlier. This foray by my grandmother and others after the Sanger case and before the One Package case was an attempt to try to gain respectability and scientific credibility for the birth control movement. It was a mistake.”⁷

Writes another pro-Abortion activist:

“The progressive potential of birth control remains indisputable. But in actuality, the historical record of this movement leaves much to be desired in the realm of challenges to racism and class exploitation.”⁸

So it does follow that as American society was leading up through the roots to penetrate the surface and have the case called Roe, the notion that abortion should be a safe and legal commodity was rejected by the political, social, religious, and medical establishments. It was a fringe belief and as an effort at attaining some form of legitimacy had many of its figureheads support a racist pseudo-science. All but the most partisan pro-Abortion advocate acknowledges that “arguments advanced by birth control advocates have sometimes been based on blatantly racist premises.”⁹ Although many women were having abortions to the unknowing of even their personal physicians, one woman would make sure that eventually anyone who wanted to get an abortion didn’t have to do it illegally.

II. Roots

As times were changing, many things once established eventually got removed by the 1960s and 1970s. This was not altogether a negative situation, as long-standing systems of exploitation and repression were destroyed. Numerous countries once under the rule of colonial magistrates either violently or passively gained independence and various ‘Jim Crow’ Laws were phased out in the USA. One of the many radical changes taking place at this time was the renewed war against anti-abortion laws. The ultimate and crucial victory for the Pro-Choice Movement was that landmark case, whose roots are full of misconceptions and errors, stemming no doubt from a movement that was dubious to begin with.

The vast entanglement of the Birth Control Movement and racial eugenics was apparently not frightening enough to prevent the Blackmun Court of the USA from making the decision to side with a Midwestern woman who wanted to get an abortion but her home state of Texas forbade it save in the event of life-for-life. The reasoning of the case, the very foundation of what would create an oft exploited Supreme Court decision, involved three major claims that have little accuracy. Claim number one: “It perhaps is not generally appreciated that the restrictive criminal abortion laws in effect in a majority of states today are of relatively recent vintage.” Given that the United States of America is a “relatively recent vintage”¹⁰ compared to world history; this does not make a good argument.

Further, it is not as though there was nothing regarding willful termination of fetuses before the 19th century. Although neither the Greeks nor the Romans had any such laws, by the Middle Ages legislation of that breed took shape. In England, one 13th century law stated what the situation was if a man gave a pregnant woman poison to terminate a pregnancy: “…if the foetus is already formed and animated, and especially if animated, he commits homicide”¹¹. 14th century documents show that cases, such as one entitled “The Abortionist’s Case”, involved prosecution for someone who purposely killed an unborn.¹²

So that claim on the part of the Supreme Court was in error. The next reason for its decision in the case was laid out: “This right to privacy…is broad enough to encompass a woman’s decision whether or not to terminate her pregnancy.”¹³ This is also an erroneous assumption, which has reaped continual damage upon the country over the last few decades. Many wonder, then, what is the problem with ‘The Right to Privacy’? The big one is that it does not exist. It started with an article in the Harvard Law Review in 1890, over 100 years after the US Constitution was written. The beliefs of the article were not acted upon until Griswold v. Connecticut (1928), which was nearly 150 years after the ratification of the US Constitution.

Although invoked in many cases before 1973, the right to privacy has never been found to be constitutional. Indeed, even Chief Justice Blackmun admits in none other than the majority opinion of Roe v. Wade: “The Constitution does not explicitly mention any right of privacy.”¹⁴ Efforts to attach the alleged right to parts of the US Constitution such as the Ninth Amendment, the Fourteenth Amendment, and even the First Amendment have all ended in failure and distinctive if not telling contradictions between cases. In a Columbia Law Review article, Professor Louis Henkin noted the problem of using privacy in Roe:

“What the Court has been talking about is not at all what most people mean by privacy…Ms. Roe sought her abortion openly, ‘publicly.’ In a word, the Court has been vindicating not a right to freedom from official intrusion, but to freedom from official regulation”¹⁵

This is problematic then, even IF a right to privacy could be classified as existing. It must be further noted that those cases that preceded Roe, many of whom are either mentioned in the majority opinion or hinted at, involved property, labor, and unlawful search and seizures. They had nothing to do with matters of life, born or unborn. And that leads us to false intellectual given number three that makes the foundation for the decision in Roe (1973): “In short, the unborn have never been recognized in the law as persons in the whole sense.”¹⁶ Justice Blackmun never considers the matter of the value of en utero life.

This landmark decision, as well as another lesser known but nevertheless controversial Court case called Doe v. Bolton, seem to be more concerned with the life of the mother and not concerned at all about the life of the child:

“Roe and Doe also have been attacked on the ground that in them, the Court paid insufficient attention to protecting the interests of the fetus—that in protecting the woman’s right to be let alone, it unnecessarily jeopardized the fetus’s ‘right to be.’ Justice Blackmun’s majority opinion attempted with little success to parry this criticism.”¹⁷

However, there is one loophole put in by Justice Blackmun regarding the unborn life in question: “If this suggestion of personhood is established, the [Prosecution’s] case, of course, collapses, for the fetus’s right to life would then be guaranteed specifically by the [14th] Amendment.”¹⁸ So is there any scientific evidence to substantiate that there is life in that there womb? Well, yes. First, one must note premature babies. In normal fetal development, the age of viability, or when a preterm baby can survive outside of the womb, is 22 weeks, or about five months. This means that abortions that take place in mid-second trimester or third trimester involve the termination of life that can be self-sufficient.

This is why many, even those who want abortion legal, hesitate regarding those last four months. Indeed, as explained later, the Blackmun Court had similar feelings in some respects. In talking with friends of mine that favor abortion, the general consensus amongst them is that after a while, the baby does get very developed and so if it happens then, it is just plain murder. What about the development of en utero life in those other trimesters? Well, it works out a lot like a preplanned system of growth, with the aim of a finished product entering the outside world. John Pekkanen explains this amazing process:

“Instructed by their genes, the cells continued to divide but didn’t always produce exact replicas. In a process still not well understood, the cells began to differentiate to seek out their own destinies. Some helped build internal organs, others bones, muscles, and brain.”¹⁹

Carl Sagan, the famous astronomer, was pro-choice. In one work, he compared the abortion of a first trimester to cutting oneself on the arm and loosing blood. He reasoned that if loosing some blood from a cut is not labeled a genocide, then why is aborting a first trimester fetus labeled murder? Well, this reasoning of course was built on bad science to begin with, as Sagan was an endorser of the long debunked Recapitulation Theory of Embryological Development.²⁰ Further, peer-reviewed science has shown otherwise: “At 19 days postconception, the earliest brain tissues began to form.”²¹ Usually when people contemporarily define life, it involves the brain and since this shows the brain’s beginnings, it is convincing evidence that life is found even then. Further, writes Pekkanen:

“Even in the earliest stage of development, the fetus knows to protect its brain. The brain gets the most highly oxygenated blood, and should there be any shortage, the fetus will send the available blood to the brain.”²²(My italics)

According to Dr. Peter Nathnielsz, a fetal researcher, reproductive medicine professor at Cornell University, and obstetrician, “We pass far more biological milestones before we are born than we’ll ever pass after we’re born.”²³ And Lise Eliot, author of What’s Going on in There? Further shows that the development of a fetus is extensive and surpasses that of a mere extra body part like the late Sagan regarded: “Babies go through the same activity patterns and behavioral states before and after birth. Well before it is born, the baby is primed to gravitate to its mother and its mother’s voice.”²⁴ Remember then the words of Justice Blackmun? He said it in the Opinion of the Court, and to my knowledge the sources above as well as numerous studies, sonograms, and so forth show that the fetal life so devalued in the abortion process is in fact just as human as any post-birth individual.

Nevertheless, either none of this was around when the Roe decision was made or none of it was attended to. Some experts, like Candace C. Crandall, indicate that prevailing social trends aided in the decision rather than any actual scientific or legal proof. She cites as a thesis that in the 1960s there was an increasingly popular view that abortion could solve social ills, namely the dreaded fear of overpopulation. “This line of thinking already had powerful support from The Population Bomb, the 1968 bestselling book by Stanford biologist Paul Ehrlich.”²⁵ This paranoia spread out and had the following disaster scenario:

“[Ehrlich] warned that humans were rapidly populating themselves out of existence. Within slightly more than a decade, he wrote, all ocean life would die of DDT poisoning. Thousands would perish in smog disasters in New York and Los Angeles. Life expectancy in the United States would plunge to just forty-two years, as pollution-induced cancer epidemics decimated the population.”²⁶

Could now-debunked ideas, such as Recapitulation Theory and The Population Bomb, have been the foundation for the reasoning of that landmark case? It is a troubling thought. Added to that insufficient legal evidence that the decision was concurrent with the US Constitution in general, make this a problem on matters exceeding choice or life. If the Federal Supreme Court could make a decision with little if any constitutional basis and make it established law, then what else can they do that no written document could stop them? Yet, for all its reputation, Roe v. Wade has a side that is unexpected and greatly ignored.

III. Trunk

When tracking the history of American slavery, historians note that there was in essence two phases of American opinion towards it. When the American Revolution was won, the belief among many slave holders and the general populace was that slavery was a ‘necessary evil’, which meant that it was morally wrong and corrupting, but needed economically to keep the fledgling republic competitive with other multi-continental regimes. Later, by the early 1800s, as that generation passed away and the next came to inherit that system, they referred to it as a ‘positive good’, totally neglecting the moral issue and instead focusing purely on the economic benefits, which for the ‘King Cotton’ South were numerous.

Abortion took a similar path through its history in the 20th century United States. When 1973 had come and the decision handed down, it was done with a compassion intended. That is to say that Roe was meant to make it easier for something that was seen as a ‘necessary evil’ to be performed. This was more or less the mentality since the USA had been founded: “Prior to 1820, all states accepted the English common law and regarded abortion after quickening as an offence.”²⁷ The exception guaranteed was always life-for-life. Indeed for most of the years since Roe v. Wade, the majority of Americans, while believing abortion should be legal, also believed that it was a detestable practice and morally unacceptable.

The new trend developing, which arose from later lesser known court cases, is the belief that abortion is not only an occasionally detestable albeit necessary procedure, but that in reality it’s a ‘fundamental right’. This is an amazing declaration since before that fundamental rights usually tended to be those written directly into the US Constitution, rather than actions very loosely interpreted as being justified by the Bill of Rights. Groups who want this practice legalized are no longer calling themselves “Birth Control” advocates, but “Abortion Rights” advocates. This name changing is found also in many established newspapers, which no longer call their opponents “Pro-life” but “Anti-abortion”.

This same movement that endorsed perverted science to get into the mainstream, twisted constitutional law, and fully ignored endless studies on fetal development has done one more injustice: distorting what the word “right” means. English is full of words abused by constant misuse, such as theory. A theory is not an opinion, but a testable hypothesis that can be debunked or vindicated by empirical science. Barking up a similar tree, a right is not just something one gets to do without being restricted, it’s something that a person is entitled to do because it does not harm the individual or the community at large. Unrestricted abortion has shown that it is not a right, for it harms both the individual and the community on many levels. Yet for decades children have been brought up with this misuse of the term, and so live in a delusion and a constitutionally dangerous one at that.

Let’s start with growingly popular lesson waiting to be taught on how correlation does not imply causation. Some have claimed that the very large number of abortions performed since Roe v. Wade prevented a great crime wave. What is the basis for this? Well, it began with a 2001 study by Steven D. Levitt, a professor of economics at the University of Chicago and John J. Donahue III, a professor of law at Stanford University. This study focused on the crime rate and its relation to the abortion rate. “The authors concluded that legal abortion disproportionately prevented potential criminals from being born with the result that the rate of violent crime would begin to decline eighteen or so years later.”²⁸ This goes back to the constantly resurfacing belief that abortion can cure social ills. Then again, as pro-choice advocate Alexander Sanger points out, it’s not the best argument to use:

“In fact, the violent crime rate did begin to decline about eighteen years after abortion was legalized in various states. But whether this was a coincidence or was caused by the legalization of abortion was another matter. Other researchers pointed out that there were many social, demographic, and economic factors behind the fall in violent crime rates in the early 1990s.”²⁹(My italics)

There is one matter that just never seems to get settled regarding the process of abortion: the harmful side effects to the mother. Abortion is already 100% deadly, as well developed fetal life, which has been shown to be more than just some extra body part, is destroyed every time. Yet there may yet be another individual at risk: the mother. Enter Mark Crutcher, founder of Life Dynamics, a pro-life group. In his disturbing book Lime 5, he unsurprisingly tackles the matter of the dangers to the one who seeks an abortion. His first chapter is a both a hit and a miss. On the one hand, he compiled a very long list of women who suffered from various side effects from having an abortion, including injuries to the uterus, cervix, and the urinary tract, incomplete abortions, anesthesia complications, and hemorrhaging.³⁰

Yet this chapter had its problem. Although he writes at its beginning that those mentioned “are only a fraction of the total number of cases found” he does not mention what amount were found, making the real danger for women questionable, when comparing potential estimates of cases found by Life Dynamics and the sheer number of annual abortions. One of those parts that he did get correct, though, was the evidence for chapter 6, which talked about the pro-life argument that there is a link found with breast cancer and abortion, especially abortions performed on a woman’s first pregnancy. He cites 24 scientific studies, which all took place in different parts of the world, each with varying economic and social conditions.

And what were the results of all this? Well, here are some of the findings for some of them: “There was a significant excess of [cancer] cases reporting one or more abortions.”³¹ “Pregnancies of less than four to five months duration may be associated with an increased risk.”³² Other studies had estimations of increased risk of breast cancer being 52%³³, 90%³⁴, and 30%³⁵. Although many criticize these peer-reviewed studies due to their reliance on memory, and ergo the alleged “recall bias” found in breast cancer patients, there are numerous other studies conducted with memory not being the primary means of attaining information and they had similar conclusions to the studies being detailed by Crutcher.³⁶

Although the old academic cliché ‘correlation does not imply causation’ could be invoked, there needs to be a note on each of these studies. All the ones that Crutcher cites in his book come from different countries, different decades, and usually target different SES and ethnic groups. The one common thread that all studies cited have in common as a situation is that of a close correlation between breast cancer and number of induced abortions. Economic and environmental trends have no real common threads. The only consistent piece of data between each study is the mutual growth of abortions and breast cancer cases.

Not too long ago the abortionist side fired back with a large-scale study known as the Melbye study, or just the Danish Study. Dr. Melbye was able to get the computerized records of 1.5 million Danish women, including of course those who had had abortions. The sample space was large because Melbye involved every Danish woman born from April 1, 1935 to April 1, 1978. This hefty study does gain strength through the larger sample space, which means a higher chance of accurately representing the general population. The study’s conclusion was that there was no connection between breast cancer and abortion. Ergo, many would assume and not without reason that the matter had been laid to rest.

I was one of those who believed that, until I read the article “Rotten in Denmark” by Dr. Joel Brind, who has dedicated much of his life to proving the existence of a link between the two entities and getting every medical institute to admit it. Some of his issues with the study were indeed contradictory at times, but otherwise this expert made some very valid points:

“The use of birth records back to 1935 meant that women in the study were as old as 38 when the computerized abortion registry began, so records of abortions among them are largely missing.”³⁷

“In fact, since abortion was legalized in Denmark in 1939…the published record of legal abortions from 1940 to 1973 reveals that 60,000 women in the Melbye study cohort listed as not having had any abortions, actually did have abortions! That means that Melbye et al., who listed 281,000 women as having abortions, misclassified more than one of every six women in the study cohort who had an abortion.”³⁸

“The inclusion of women born as recently as 1978 inflates the population size studied by over 350,000 subjects. That is the number of women born between 1968 and 1978, who were therefore under 25 at the termination of the study in 1992. Almost no one gets breast cancer that young.”³⁹

After Roe, many new cases came forth and contradicted the proclaimed law of the land. This series of cases that seemed to negate all that was accomplished in 1973 became collectively known in some pro-choice circles as ‘The backlash’. Using the loose definition for that statement, the United States is still going through this apparently spontaneous effort to restrict, remove, or otherwise inhibit Roe and the abortion practice that it is said to have completely legalized. Of the many that could be analyzed, an interesting one has to be the 1989 case Webster v. Reproductive Health Services. In Webster, “[t]he court upheld a Missouri law prohibiting the use of public employees and public facilities for the purpose of performing abortions that were not medically necessary.”⁴⁰ Many in the Pro-Abortion camp look upon this case with concern, deeming its permitted restrictions as “wide-ranging.”⁴¹

What makes it interesting is that even though that landmark 1973 case was supposed to have given abortion access no abuse, this did not stop that the Supreme Court from deciding the way it did. As part of the majority opinion reads: “Section 188.029 of the Missouri statute…is constitutional, since it permissibly furthers the State’s interest in protecting potential human life.”⁴² This means that the Webster case was decided on using what appears to be from this vantage point on the arboreal scene to be something contradicted by Roe. This and other pieces of legislation and judicial rulings appear to be rolling back the potent case of 1973, and yet as one is about to find out by climbing the tree of Roe and looking at the real world while balanced on its branches, the situation is far different.

IV. Branches

Roe v. Wade, the landmark Supreme Court decision that has passed its 30th birthday, continues to gather controversy and divisive debate. Some want it to be a litmus test for government positions and others want it to be overturned. Many dedicate their lives to protect it and all it supposedly stands for, whilst others devote themselves to gradually removing it via turning to the state and federal legislatures. And yet has anybody involved in this actually bothered to read the majority opinion of Chief Justice Blackmun, the man who wrote the majority opinion for that court in 1973? Well, it is an interesting idea, actually understanding highly publicized and controversial documents, knowing what they state on various matters.

Pro-lifers, knowledgeable that in the end that infamous decision decriminalizes overall abortion,tend to not read the demoralizing pages. Pro-abortion advocates, convinced of the absolute right offered by the case’s decision, do not seem to bother quoting the case on their websites to make their arguments. Several pro-choice groups, like Planned Parenthood, speak of the dangers of “anti-choice zealots” who would strictly regulate and eventually outlaw the abortion procedure. As they say in an online article that “For a number of reasons…abortion after the first trimester remains a necessary option for some women”⁴³ and then reject any notion of regulations. The same is found with the typical pro-Abortion intellectual, who believes that “the most basic aspect of abortion rights--the fact that abortion is fundamentally a woman’s right to decide, at any point in pregnancy, for any reason.”⁴⁴

However, to everybody’s surprise Roe v. Wade encourages restrictions on abortion. As Justice Blackmun wrote in the Opinion of the Court, “some amici argue that the women’s right is absolute and that she is entitled to terminate her pregnancy at whatever time, in whatever way, and for whatever reason she alone chooses. With this we do not agree.”⁴⁵ Let me repeat that last line, “With this we do not agree.” In other words, by Planned Parenthood’s standards, Justice Blackmun is an anti-choice zealot. The position of many abortion groups in favor of the partial birth abortion procedure contradicts Roe: “the right, nonetheless, is not absolute and is subject to some limitations; and that at some point the state interests as to protection of health, medical standards, and prenatal life, become dominant.”⁴⁶

Apparently Roe doesn’t only contradict the beliefs of pro-choice groups like NARAL, but also the National Organization for Women (NOW). On the “Reproductive Rights Historical Highlights” section of their website, they consider court cases that restricted abortion access to be ‘backlash’ to Roe, and described President Bush’s signing the Partial Birth Abortion ban into law “while surrounded by a group of smiling men.”⁴⁷ Yet this supposed backlash is completely compatible with Roe, as Justice Blackmun wrote: “The decision leaves the State free to place increasing restrictions on abortion as the period of pregnancy lengthens”.⁴⁸

There is no doubt that Roe v. Wade decriminalizes some abortion procedures, but to say that it did so completely is incorrect. Using the standard of Roe, most of the pro-abortion groups in the country are encouraging the breaking of law, yea even law that they claim they want as the established edict of the land. This noted error on the part of pro-choice can be added to the strong ties to the racial eugenics movement in its nascent years, the weak legal argument of Chief Justice Blackmun, the perversion of the word ‘right’, and the harmful side-effects inflicted upon the unsuspecting mother. Those are a lot of problems with one movement.

V. The Fruit

By now, it has no longer become an issue of choice, but that of survival and moral decency. The pro-choice movement’s major chapters are full of historical distortions, weak legal arguments, and blatant refusal to acknowledge the value of human life before birth. Increasingly scientific studies are invalidating the abortion movement by showing that there is just as much life to the child as there is to the mother, and more legal scholars are doubting the established tree of Roe. The axes are shiny, and they are prevailing even as the terms like right and choice don’t have their proper meanings emphasized.⁴⁹

There is not a single point made by pro-abortion groups regarding planned families that could not be remedied by abstinence and personal responsibility, the very things that they hold as a preferred standard. So the next time a judge is appointed that believes restrictions should be placed on abortion access, realize that he or she is perfectly in tune with what was demanded 33 years ago in a controversial and much misunderstood decision. Everything must be used to pull the weed of Roe.

Sources:

1. Jones, David Albert, The Soul of the Embryo (New York: Continuum,2004) pp.198-199.

2. Whitney, Catherine, Whose Life?(New York: William Morrow and Company, Inc.,1991) p.44.

3. Robert M. Baird and Stuart E. Rosenbaun (Eds.) The Ethics of Abortion (3rd Ed.) (Amherst, New York: Prometheus Books,2001) p. 65. Opinion of the Court originally published in United States Reports, vol. 410, pp. 113-178. Cases Adjudged by the US Supreme Court during the October Term, 1972.

4.The World Book Encyclopedia (Vol.6) E, World Book, Inc., Chicago, p.377.

5. A couple good examples are described here: http://www.albertasource.ca/alphabet/article.php?article_id=234 and http://www.eugenicsarchive.org/html/eugenics/essay8text.html, both accessed July 25th, AD 2006.

6. Sanger, Alexander, Beyond Choice(New York: Public Affairs,2004) p.57.

7. Sanger, p.59.

8. Essay found in Marlene Gerber Fried (ed.) From Abortion to Reproductive Freedom: Transforming a Movement (Boston, MA: South End Press, 1990) p.15.

9. Fried, p.15.

10. Baird and Rosenbaun, p.64.

11. Bracton, The Laws and Customs of England, cited in Dunston 1988, p.47, itself cited in Jones, David Albert, The Soul of the Embryo (New York: Continuum,2004) p.194.

12. In The Soul of the Embryo, Jones wrote: “’The Abortionist’s case’ of 1348 shows that abortion was regarded as worthy of criminal prosecution even in the Middle Ages, but in the event the alleged perpetrator was acquitted because of the difficulty in determining the cause of the child’s death.” (p.196)

13. Baird and Rosenbaun, p.66.

14. Baird and Rosenbaun, p.66.

15. Ralph A. Rossum and G. Alan Tarr(ed.s), American Constitutional Law (2nd Ed.) (New York: St. Martin’s Press, 1987) p.625.

16. Baird and Rosenbaun, p.69.

17. Rossum and Tarr, p.625.

18. Baird and Rosenbaun, p.67.

19. Pekkanen, John, “The Mystery of Fetal Life: Secrets of the Womb”, Current, September 2001, p.21. Originally printed as “Secrets of the Womb”, John Pekkanen, The Washingtonian, August 2001, pp. 44-51, 126-135.

20. This debunked view, created by Ernst Haeckel in the 19th century, held that fetal life of all species went through their original evolutionary stages while developing in the womb. Although extensive research, notably in 1997, showed that this was not the case, it has nevertheless been used on some occasions to biologically justify abortion. Sagan’s statements endorsing said debunked theory can be found in Sagan, Carl The Dragons of Eden (New York: Random House, 1977) pp.57-58.

21. Pekkanen, p.21.

22. Pekkanen, p.21.

23. Pekkanen, p.22.

24. Pekkanen, p.28.

25. Torr, James D. (Ed.) Abortion: Opposing Viewpoints (New York: Green Haven Press, 2006) p.61. Originally found in Crandall, Candace C., "Thirty Years of Empty Promises", First Things, January 2003, pp.14-17.

26. Ibid.

27. Jones, p.199.

28. Sanger, p.67.

29. Ibid.

30. Crutcher, Mark, Lime 5 (Denton, Texas: Life Dynamics, Inc., 1996) pp.20-82.

31. M. Ewertz and S.W. Duffy, “Risk of Breast Cancer in Relation to Reproductive Factors in Denmark”, British Journal of Cancer, Vol. 58 (1988), cited in Crutcher, Mark, Lime 5 (Denton, Texas: Life Dynamics, Inc., 1996) p.225.

32. P. Mirra, P. Cole; B. MacMahon, “Breast Cancer in an Area of High Parity”, Cancer Resources, Vol. 31 (1971), cited in Crutcher, Mark, Lime 5 (Denton, Texas: Life Dynamics, Inc., 1996) p.225.

33. V.V. Dvoirin and A.B. Medvedev, “The Role of Reproductive History in Breast Cancer Causation”, Methods and Results of Studies of Breast Cancer Epidemiology, Tallinn, Estonia (in Russian) (1978) cited in Crutcher, p.226.

34. H.L. Howe et al., “Early Abortion and Breast-Cancer Risk Among Women Under 40”, International Journal of Epidemiology, Vol. 18 (1989) cited in Crutcher, p.226.

35. F. Parazzini et al., “Spontaneous and Induced Abortions and Risk of Breast Cancer”, International Journal of Cancer, Vol. 48 (1991) cited in Crutcher, p.226.

36. The footnotes in Crutcher’s book Lime 5 for this fact, numbers 46 and 47 on page 305, list a combined total of 9 studies.

37. Dr. J. Brind, “Rotten in Denmark”, http://abortion-not.org/brindmelbye.htm (accessed July 24, 2006)

38.Dr. J. Brind, “Rotten in Denmark”, http://abortion-not.org/brindmelbye.htm (accessed July 24, 2006)

39. Ibid.

40. http://www.now.org/issues/abortion/roe30/timeline.html (Retrieved July 24th, AD 2006)

41. Fried, p.5.

42. http://www.law.cornell.edu/supct/html/hitorics/USSC_CR_0492_0490_ZS.html (Retrieved July 24th, AD 2006)

43. http://plannedparenthood.org/pp2/portal/files/portal/medicalinfo/abortion (accessed July 23rd, AD 2006)

44. Fried, pp.7-8.

45. Baird and Rosenbaun, p.67.

46. Ibid.

47. http://www.now.org/issues/abortion/roe30/timeline.html (Retrieved July 24th, AD 2006)

48. Baird and Rosenbaun, pp.70-71.

49. Even Pro-Choicer Fried admits, “The notion that abortion is morally problematic is growing.” (Fried, p.5.)