The Log College

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The contemporary frequency of parents, especially mothers, killing their children—not only newborn babies but toddlers too—is a new phenomenon. Does this have something to do with the relentless loosening of abortion laws in America since Roe v. Wade? We live in an era where we pretend that we do not know when life begins, but we certainly do know when it ends and how to end it.

In light of the passage of the New York state abortion statute exactly one year ago that brought the issue of “infanticide” into national consciousness for the first time, the fundamental role that abortion has played for a long time in the moral and political division of the country—its importance rivaled only by Brown v. Board of Education—and the certainty that abortion will be an even more important issue in the November 2020 presidential elections even than it has been in the past, this essay attempts a review of the legislative, judicial, political, and social developments of recent years in regard to abortion.

The precipitating event has been the New York abortion statute enacted after the capture by the Democratic party of the New York state senate in the 2018 elections, ending thirty years of Republican control of that body, to go along with the Democrats’ long-standing control of the state Assembly, and with Democratic governor Andrew Cuomo the Democrats controlled the New York state government completely. The party made abortion its first order of business when the new legislature convened in January 2019. The motivation, as explicitly stated by Gov. Cuomo, was to codify Roe v. Wade into New York state law because of the fear that the Supreme Court might overturn it.

In Roe, the Supreme Court spoke of “potential life” and said that it need not decide the supposedly “difficult question of when life begins.” Even though Justice Blackmun for the Court did not know, the science of embryology knew the answer to the question then and now: “the sex of the new individual . . . is determined at fertilization” (Langman’s Medical Embryology, p. 41).[1] The ruling of Roe, together with its companion case, Doe, made abortion available throughout the nine months of pregnancy, the actual equivalent of infanticide, in the last months. That fact was scrupulously ignored and suppressed by the mainstream media and by feminist and other progressive advocacy groups. Until 2019, it had never become a public and national issue. Roe invented a new constitutional right, available only to women: a “right of privacy” then and now restated as a woman’s “right to control her body.” In the 7-2 Roe majority were Justices Willam Douglas, Thurgood Marshal, William Brennan, Potter Stewart, Harry Blackmun, Lewis Powell, and Warren Burger, the last five of whom had been appointed by Presidents Eisenhower and Nixon.

Roe had ambiguously allowed a state, “in promoting its interest,” in what it called “the potentiality of human life,” to “proscribe” abortion “subsequent to viability,” that is, the point at which a baby may be expected to live outside the womb. The Court said that “Viability is usually placed at about seven months (28 weeks) but may occur earlier, even at 24 weeks. . . . [t]he infant has a 90% percent chance of surviving” if born at “6.5 to 7 months” after fertilization.[2] But the exceptions of not only the “life” of the mother but also her health” essentially undermined the “proscribing” authority of states. In Roe’s companion case, Doe v. Bolton, the Court and concurring opinions extensively discussed and made clear that the “health” basis for an abortion includes “mental” health, that is, “health in the broadest medical context” and “psychological as well as physical well-being,” and that it applied throughout the nine months of pregnancy. Likewise, in the later abortion case, Casey (1992), the Court, with similar equivocation had recognized a state’s “power to restrict abortions after viability” and a state’s “legitimate interests” in “the life of the fetus,” up to and even including a “legislative ban on nontherapeutic abortions.” But the Casey court followed up on the Roe court’s smokescreen by providing that a state law may not place an “undue burden” of a woman’s right to abortion supposedly before viability, but other places in the opinion used language to establish that as a standard throughout pregnancy, that is, after “viability.” And this was more explicitly enlarged in the Whole Woman’s Health case (2016).

From the beginning of the abortion era, many states reacted to Roe by attempting to restore some version of their abortion laws, and with the motivation of trying to establish some kind of protection for the independent, sensate reality of the unborn child. (“During the fifth month, movements of the fetus can be felt by the mother.”[3]). In the 47 years since Roe, the Supreme Court has handed down approximately 20 major abortion decisions, all prompted by the continuing rejection by the states of Roe. There is no other issue like it.

New York and Virginia in 2019

Even after Roe, the state of New York continued its outright prohibition of abortion after 24 weeks, except when the woman’s life was in danger. With the leadership of Gov. Cuomo, and the fear in progressive circles that the Supreme Court might overturn Roe, the specific purpose of the new statute is to repeal that provision of the law. The new wording establishes the right to abortion at any time if there is an “absence of fetal viability” or to protect the woman’s “life or health.” Thus, with decades of practice beginning with Roe and Doe that a woman’s “health” includes mental health and with the vague concept of “fetal viability,” it is clear that New York has established a right to abortion at any time during pregnancy. And as New York state senator, Liz Krueger, a main sponsor of the New York bill, said, abortion “later in pregnancy,” can be indicated by a “woman’s mental health.”[4]

Nonetheless, with the support of the New York and national media, Gov. Cuomo himself authored an opinion in the New York Times that disguised and denied his own explicit purpose when he said that the new law “does not allow abortions minutes before birth, nor does it allow third-trimester abortions ‘for any reason’,” and said that “third-trimester abortions are extremely rare, making up only about 1 percent of all abortions.”[5] He also disguised that misrepresentation by changing the subject from human life to attacking “the religious right” and professing his own Catholicity and stating that “most Catholics are pro-choice.”

Gov. Cuomo’s new law is in keeping with the state code of New York which, unlike three-fourths of the states, has no criminal statute outlawing the fetal homicide that is the result of a violent attack on a pregnant woman.

Likewise, and at the same time and for the same purpose, a proposed Virginia state law, strongly supported by Democratic governor, Ralph Northam, a pediatric neurologist by trade, had the specific purpose of extending abortion into the third trimester. Its specific language provided that abortion “after the second trimester of pregnancy” was permitted if a physician determines that the continuation of the pregnancy would be “likely” to “impair the mental or physical health of the woman.” In introducing the bill into the Virginia legislature, Virginia state Delegate Kathy Tran said that the bill would be “changing the standard” for third trimester abortions and would allow abortion “through the third trimester all the way up to forty weeks” and when a woman was “dilating.”[6] Gov. Northam went further and said that “[t]he infant would be delivered; the infant would be kept comfortable; the infant would be resuscitated if that’s what the mother and the family desire, and then a discussion would ensue between physicians and the mother.”[7]

Now, the Virginia Democrat party, via the 2019 state legislative elections, controls the entire Virginia state government. Like New York in 2019, the Democrats have made abortion their first order of business. Although final details of different versions of the two legislative houses have not been worked out, the bills are directed at eliminating state restrictions, such as who may perform abortions and parental consent, on abortion. With Governor Northam, a new abortion law is certain to be enacted. Supporters have said that they want to make Virginia the new “safe haven” for abortion. Significantly and unlike 2019, Democrats avoided any legislative measure intended  to ensure that abortion is available until birth.

Viability, Eugenics, and Partial-Birth Abortion Today 

As for “fetal viability” and “infanticide,” the Supreme Court in the 2019 Box case let stand a decision of the Seventh Circuit that held Indiana’s new statute unconstitutional because it prohibited abortion before viability. The state had enacted a statute, the Abortion Nondiscrimination Provision, outlawing pre-viability abortions based on the discriminatory categories of “race, color, national origin, ancestry, sex,” or upon a diagnosis or potential diagnosis of “Down syndrome” or “any other disability.” In rejecting the case, the Supreme Court said that not enough appeals courts had yet ruled on “this kind of law.” In its essentially jurisdictional ruling about the absoluteness of “viability” as the key issue, the Seventh Circuit had avoided any recognition or discussion of those civil-rights and eugenic limitations on abortion. Although agreeing with what was a jurisdictional decision of the Court, Justice Thomas wrote a long “concurrence” reviewing the history of American eugenics and its connection to abortion. Justice Thomas accused the Indiana case of highlighting “that abortion is an act rife with the potential for eugenic manipulation.” He pointed out that the Supreme Court had approved of eugenics in its never-overturned “three generations of imbeciles are enough” decision in Buck v. Bell (1927). Justice Thomas did not mention that the Buck v. Bell vote was 8-1 against the imbeciles. He also did not bring up Roe’s citation of Buck as a case supporting the Roe decision. Citing research, Justice Thomas said that the abortion rate for babies diagnosed with Down Syndrome is 67 percent in this country and much higher in Europe. Additionally, he referred to what is now commonly known about the ubiquity of sex-selection abortions in China and India.

Justice Thomas argued that Casey “did not decide whether the Constitution requires States to allow eugenic abortions.” Pennsylvania, he said, had in 1991 enacted a ban on race, sex, or disability abortions, but Planned Parenthood, the plaintiff in Casey, had not challenged that part of Pennsylvania’s law. During the pendency of the Box case in the Seventh Circuit, Washington Post editorial-page-editor Ruth Marcus, in a vociferous justification, said that she had had the pregnancies of her two born children tested in the womb and asserted that “I would have terminated those pregnancies had [Down syndrome] testing come back positive.”[8]

In Gonzalez v. Carhart (2007), the Supreme Court upheld the federal Partial-Birth Abortion Act of 2003, 18 U.S.C. §1531, the terms of which apply to any stage of pregnancy. Justice Kennedy wrote the opinion for the five-man majority. He pointedly held that part of Casey included the right of a state to be interested in fetal life, that the Act concerned an abortion method only, and did not impose an “undue burden” on the right to an abortion. Justice Kennedy referred to “dilation and evacuation” as “the usual abortion method” in the “second trimester,” described it in detail, including “collapsing the skull,” and said that it was “the impetus” for the Partial-Birth Abortion Act, although the Act applied only to “a living fetus” and, therefore, did not prohibit dilation and evacuation. He also said that after the first trimester, “most” abortions occur in the second trimester. He said along the way in his lengthy opinion that “a fetus is a living organism within the womb” that “may become a child.” The appeals court had ruled the statute unconstitutional because it did not have an exception for the “health” of the mother. The Act had been passed in the Senate by 47 Republicans and 17 Democrats; in the House by 218 Republicans and 63 Democrats.

It has to be wondered how and whether New York’s newly enacted law of 2019 and the proposed but not-enacted 2019 bill in Virginia comport with the Partial-Birth Abortion Act, which prohibits a “partial-birth abortion”[9] in which the person performing the abortion

deliberately and intentionally vaginally delivers a living fetus until, in the case of a head-first presentation, the entire fetal head is outside the body of the mother, or, in the case of breech presentation, any part of the fetal trunk past the navel is outside the body of the mother, for the purpose of performing an overt act that the person knows will kill the partially delivered living fetus; and performs the overt act, other than completion of delivery, that kills the partially delivered living fetus. [Emphasis added.]

In his opinion, Justice Kennedy made the point that the Act applied “for purposes of criminal liability” only when “the overt act causing the fetus’ death must be separate from delivery.” So, it seems that the overt killing act can occur right before delivery.

Under current federal law, the “death” of or “bodily injury to . . . an unborn child” caused in the perpetration of stated list of federal violent crimes is itself a separate crime. The “unborn child” is defined as “a member of the species homo sapiens, at any stage of development, who is carried in the womb.” 18 U.S.C. §1841. It was enacted in 2004 as the Unborn Victims of Violence Act by sixty percent majorities in both the House and Senate. Thirty-eight states have similar laws.

Three 2019 Cases After New York and Virginia 

In three cases in 2019, all based on responses to and in the context of the New York and Virginia abortion initiatives, federal district courts completely avoided any consideration of the issue of human life, including the supposed “potentiality”—or actuality—of the child in the womb by concluding in all three cases that the only thing that mattered was Casey viability. Georgia, Ohio, and Mississippi states had enacted laws prohibiting abortion after the heartbeat is perceived which is well before viability, of course. Their purpose was to have the Supreme Court confront and overturn Roe—exactly Gov. Cuomo’s fear—by enacting state laws that directly challenged it. In the Georgia case, the legislature, responding to the New York infanticide law, banned abortion after “a detectable heart beat.” The federal court in Georgia held that viability is “the most central principle of Roe v. Wade” and that no state interest in “potential life” can override that. The new Georgia law, the Living Infants Fairness and Equality Act, provided that a “natural person” includes an unborn child which is “a member of the species homo sapiens at any stage of development . . . carried in the womb.” The court found this “unconstitutionally vague” when, of course, the legislature was making it precise, doing the exact opposite. The court also gave a racial aspect to its decision, saying that black Georgians have four times the abortion rates as whites.

As for heartbeat, the court agreed with the challenge to the Georgia law and stated that “cells that eventually form the basis for development of the heart later in pregnancy produce cardiac activity that is generally detectable—via ultrasound—beginning at approximately six weeks LMP [from a woman’s last menstrual period]” (emphasis added). (“The heart begins to beat at approximately 21 days of gestation.”[10] In the Ohio case, the legislature, citing “the ongoing advancement of medical technology,” banned abortion after a detectable heartbeat. But the federal district court, relying completely on and citing Casey, ruled that viability was “the critical fact” and “most central principle of Roe.” In the Mississippi case, the federal district court concluded that viability must be determined “on a case-by-case basis.”

From “Right of Privacy” to “Meaningful Life”

For these courts, the supposed constitutional rights and rulings of Roe and its progeny cases are not enough. Abortion is not only a unique and super constitutional right, it goes beyond that. The Georgia court said that abortion is “essential to a person’s dignity, equality, and ability to shape a meaningful life.” The Mississippi court, citing Casey, said that it is “a woman’s free choice, which is central to personal dignity and autonomy.”

Indeed, Justice Rehnquist in his dissent in Casey spoke of Roe’s “all encompassing ‘right of privacy.’ ” In Bellotti v. Baird(1979), Justice Powell, writing for the Court, called it “a constitutional right of unique character.” In Casey (1992), the three Republican-appointed co-authors of the opinion of the Court, Antony M. Kennedy, Sandra Day O’Connor, and David H. Souter, said that the only other “rare, comparable” case of the stature of Roe “in our lifetime” was Brown v. Board of Education.

In Dred Scott (1857), the question was whether black slaves and free men were “citizens” under the United States Constitution and under the laws of most of the states, not whether blacks were “persons.” In numerous passages, the opinion for the 7-2 Court spoke about blacks as persons, including the phrase “separate class of persons.” But, concerning the two sections of the Constitution concerning the slave trade that the Court construed (I.2 & I.9), the Court said that black people “are not included, and were not intended to be included, under the word ‘citizens’ in the Constitution.” Dred Scott, of course, was before the ratification of the Fourteenth Amendment, which language of “person” the Supreme Court in Roe specifically denied included the unborn: “The word ‘person’ as used in the Fourteenth Amendment does not include the unborn.” The Fourteenth Amendment was ratified in 1868.

Three years after Dred Scott, the American Medical Association in 1860 sent a “Memorial” to each state legislature and governor. Explicitly based on the modern and up-to-date development in the science of embryology, that is, “actual and various proof.”[11] The key passage in full of the Memorial was:

The moral guilt of Criminal Abortion depends entirely upon the real and essential nature of the act. It is the intentional destruction of a child within its parent; and physicians are now agreed, from actual and various proof, that the child is alive from the moment of conception.

The Current and Unprecedented Politics of Abortion

Besides “socialism,” abortion is the clearest of all issues that define the differences between the two political parties. Even as late as the Clinton presidency, it was satisfactory for Democrats to say of abortion merely that it be “safe, legal, and rare.” The 1996 platform said: “less necessary and more rare.” But the 2008, 2012, and 2016 Democratic party platforms stated that the party “unequivocally” supported “safe and legal” abortions, although with the qualifying language of its goal to “reduce the need for abortion.” The 2016 platform called for the first time for a repeal of the Hyde amendment which prohibits federal funding of abortion and which had been in effect since 1976.

The Republican party has long stated its support for the “right to life” and a human-life constitutional amendment outlawing all abortion. The section on abortion of the 2016 platform was lengthy and detailed. The Republican party supported a human life amendment, the appointment of judges who “respect” the “sanctity of innocent human life” informed and parental consent laws, adoption assistance and counseling that encourages women “to choose life,” “born alive” laws for “an infant who survives abortion,” laws outlawing “pain capable abortions,” laws outlawing sex-selection and disability-selection abortions, and opposed the selling of fetal body parts. The 2012 Republican platform had spoken of the “barbaric practice of partial-birth abortion” and its opposition to “sex-selective” abortion and its support for legislation banning abortion of “unborn children who are capable of feeling pain.”

At issue in the Gee abortion case scheduled for oral argument in the Supreme Court on March 4 is a suit by abortionists challenging a recently enacted Louisiana law that requires them to have admitting privileges at local hospitals. After concluding after hearings that health and safety incidents occurred disproportionately more at abortion clinics as compared to other out-patient clinics, the legislature had decided to include abortionists, the only kind of doctor in Louisiana not previously required to have such privileges, to refer women patients with complications to local hospitals. Gee is a variation on the similar fact pattern in Whole Woman’s Health in which the Supreme Court overturned a similar Texas law as an “undue burden” on a woman’s right to an abortion.

A total of 197 members of Congress, including presidential candidates Elizabeth Warren, Bernie Sanders, Kamala Harris, Cory Booker, Kirsten Gellibrand, Amy Klobuchar, and Michael Bennett, along with party leaders Chuck Schumer and Nancy Pelosi, have filed an amicus brief in Gee asking the Court to overturn the Louisiana law. Likewise in the 2018 Becerra case, in which the Supreme Court, by only a 5-4 vote, the narrowest of margins, overturned a newly-enacted California statute requiring anti-abortion women’s clinics to post pro-abortion information concerning referrals for and the availability of abortion, that is, to speak in support of a moral position against their consciences. Senators Harris, Booker, Sanders, and Warren, along with other Democrats, a total of 16 Democrat senators and 85 Democrat representatives, including Nancy Pelosi, filed a brief in favor of that unprecedented coercion of free speech. In February, 2019, Senate Democrats blocked the Born-Alive Abortion Survivors Protection Act, introduced by Republican senator Ben Sasse, from coming to a vote. The bill, an attempted national response to the New York and Virginia developments, would have required doctors to save the life of a child born alive after an attempted abortion. Sen. Sasse had openly described the bill as an “infanticide ban.”[12]

All the Democratic presidential candidates, remaining and withdrawn, have included strong support for abortion in their campaigning. Peter Buttigieg, a Rhodes scholar (but not an embryologist), took it to the next level when he said that “how life begins” is a “cosmic question” and proposed that the abortion issue be decided by birth—claiming the Bible endorses that conclusion: “Then again, there’s a lot of parts of the Bible that talk about how life begins with breath, and so even that is something that we can interpret differently.” Mr. Buttigieg, thereby, like Gov. Cuomo, made abortion a religious rather than a legal and constitutional issue.[13] Elizabeth Warren has endorsed abortion throughout pregnancy if there is a “fetal abnormality.”[14] Bernie Sanders, when asked about third-trimester abortions, said that the decision “belongs to a woman and her physician.”[15] Former presidential candidate Beto O’Rourke had said the same thing. Joe Biden essentially agreed when he asserted that he would codify Roe v. Wade into federal law, thereby seeking to make any new Supreme Court decisions on abortion irrelevant, and said that he would overturn the Hyde amendment which has prohibited federal funding of abortion since 1976.

In the 2016 presidential election, Donald Trump campaigned more explicitly on abortion than any previous Republican presidential candidate. He brought up the issue of late-term abortion and has continued to speak out against late term abortions as president. He has made abortion a centerpiece of his presidency. He reinstated the “Mexico City Policy,” regarding federal funding of non-governmental agencies (NGO’s) active in foreign countries. Barack Obama had repealed it. He promised to appoint pro-life judges and has advocated that the Supreme Court should return the issue to the states. In 2019, his Department of HHS promulgated a new rule under Title X of the Public Health Service Act, the federal program that provides funding for birth control, that prohibits funds recipient from referring clients for abortions. President Trump supported Senator Sasse’s Born-Alive Abortion Survivors Protection Act. Mr. Trump’s Department of Justice has filed a brief in the Gee case supportive of Louisiana’s law. On January 20, 2020, on essentially a partisan vote, the Democratic majority of the House rejected by a vote of 219-187 an amendment to the Safe Drinking Water Act that would have added “the unborn child” to the “vulnerable populations” protected by the Act. Pregnant women are already designated in the Act as an “at risk” group.[16]

In the context of this sharpest of political divides have been allied initiatives to promote abortion. Instead of a “private choice,” there is a new rhetorical tactic of “shouting your abortion.”[17] At a movie awards this year, the shouting of Michelle Williams, apparently an actress, that her own abortion was a key to her successful career received widespread national publicity. A new California law requires all public colleges to make abortions available on campus. In June, 2019, a new campaign asserting that restrictions on abortion are “bad for business,” was launched in a full-page ad in the New York Times.[18] Among the better-known businesses or businesspersons appearing in the ad, were Bloomberg LP, Yelp, Ben & Jerry’s, and Tinder. At the same time, Netflix and Disney threatened to stop producing movies in Georgia because of its new abortion law.

Late-Term Abortions Are “Rare”

Against accusations that third-trimester abortions are infanticide, a uniform response by the elite media and the Democrat Party has been that such abortions are “rare.” As already mentioned above, Gov. Cuomo has said that such abortions are “extremely rare.” And Elizabeth Warren has stated that “infanticide is illegal everywhere in America.”[19] Former Planned Parenthood President Leana Wren has said that “[a]bout 1% of abortions occur after 24 weeks, and when they do occur, they are often due to complex circumstances.”[20]

But to use as an argument that late-term abortions are rare is to accept those “rare” late-term abortions. How rare? According to the Center for Disease Control, there were 7,481 abortions (1.2%) performed at or after 21 weeks gestation in 2016.[21] According to the Alan Guttacher Institute, there were 862, 320 abortions in 2017, of which 11,210 were performed at or after 21 weeks gestation.[22] As already referenced above, a child born at 6.5 to 7 months has a “90 percent” chance of survival.

In 2012, the Journal of Medical Ethics (est: 1975) had published a paper entitled “After-birth abortion: why should the baby live?”, in which the co-authors argued that,

If criteria such as the costs (social, psychological, economic) for the potential parents are good enough reasons for having an abortion even when the fetus is healthy, if the moral status of the newborn is the same as that of the foetus and if neither has any moral value by virtue of being a potential person, then the same reasons which justify abortion should also justify the killing of the potential person when it is at the stage of a newborn.[23]

Such logic is a natural extension of Roe. And, of course, there is Princeton University professor Peter Singer’s stance, clearly set out in his Practical Ethics (1980), now in its third edition, “justifying infanticide.”[24]

Abortion and Homicide

Does this have something to do with the apparent rise in mothers killing their born children? In California in 2019, the mother of a newborn and her boyfriend are alleged to have strangled their baby in the hospital.  In Ohio, a woman pleaded guilty last year to killing her three children on three separate occasions over a two-year period. A mother in Boston is alleged to have killed herself and her two children, ages four and sixteen-months, by throwing them and herself off a building in December 2019. In Louisiana in 2019, a mother was charged with murder of her five-year-old daughter after falsely claiming that the child died in an automobile accident. In Alabama, a mother was arrested for allegedly murdering her two sons, ages 9 and 3, in 2019. In Texas, a mother is alleged to have killed herself together with her six-year-old son in 2019. A grandmother in Arizona was just sentenced this year for the 2019 murder of her two autistic twin grandsons.

And fathers: In New York City in 2019, a father is said to have murdered his 5-year-old daughter and beheaded his wife before killing himself. In Florida, a man has been charged with killing his wife and her four children, ages 1, 2, 5, and 10 in 2019.  And the murders of his wife and two daughters, ages 3 and 4, by Colorado father Chris Watts has been continuously in the news since the crimes and his guilty plea in 2018 and are now the subject of two separate movies.

This writer of sufficient age and personal memory reaching back to 1973 contends that the contemporary frequency of these kinds of child killings is a new phenomenon. They occur in the era of abortion where we pretend that we do not know when life begins, but we certainly do know when it ends and how to end it.

The Imaginative Conservative applies the principle of appreciation to the discussion of culture and politics—we approach dialogue with magnanimity rather than with mere civility. Will you help us remain a refreshing oasis in the increasingly contentious arena of modern discourse? Please consider donating now.


[1] Langman’s Medical Embryology, T.W. Sadler, 14th Edition (2019), p. 41.

[2] Langman’s, p. 109.

[3] Langman’s, p. 106.

[4] Liz Krueger, FAQs about the Reproductive Health Act, February 12, 2019.

[5] Andrew M. Cuomo, “Andrew Cuomo: Trump’s Assault on Abortion Rights Must Be Rejected,” February 6, 2019.

[6] “Kathy Tran Presents Virginia Third Trimester Abortion Bill in Committee,” YouTube video, 6:41, “The Republican Standard,” January 29, 2019. (“Dilating” at 1:10.)

[7] Rick Massimo, “Virginia Gov. Northam on road projects, teacher pay, shutdown impact, more,” WTOP, January 30, 2019.

[8] Ruth Marcus, “I would’ve aborted a fetus with Down syndrome. Women need that right.” March 3, 2019.

[9] Partial Birth Abortions Prohibited, 18 U.S.C. §1531 (2003).

[10] Langman’s, p. 221.

[11] Frederick N. Dyer, “The Documents that Produced the Laws Overturned by Roe v. Wade,” n.d.

[12] U.S. Senator for Nebraska Ben Sasse, “Democrats Block Sasse’s Infanticide Ban,” by Ben Sasse, February 4, 2019.

[13] The Breakfast Club (2019) iHeart Radio 6, 9. (At 37:27.)

[14] Maggie Astor, “How the 2020 Democrats Responded to an Abortion Survey,” November 25, 2019.

[15] “Bernie Sanders Dodges On Third Trimester Abortions,” YouTube video, 0:45, “America Rising ICYMI,” April 15, 2019.

[16] Congressional Record, pp. 162-63, Jan. 10, 2020.

[17] Shout Your Abortion.

[18] Sinéad Baker, “187 companies, including Bloomberg, Tinder, and Ben & Jerry’s, teamed up to slam abortion restrictions sweeping Southern states,” Business Insider, June 11, 2019.

[19] “Warren Heckled At Iowa Event,” YouTube video, 0:57, “TheDC Shorts,” March 1, 2019.

[20] Leana Wen (@DrLeanaWen), “I’m a doctor so I have to look at the facts. About %1 of abortions occur after 24 weeks, and when they do occur, they are often due to complex circumstances. Just take Alexis’ story.”, Twitter, February 5, 2019.

[21] Centers for Disease Control and Prevention, “Reproductive Health.”

[22] Guttmacher Institute, Induced Abortion in the United States (September 2019).

[23] Alberto Giubilini, Francesca Minerva, “After-birth abortion: why should the baby live?” Journal of Medical Ethics 39, no. 5 (2013): 261-263.

[24] Peter Singer, “Taking Life: Humans,” in Practical Ethics (Cambridge, UK: Cambridge University Press, 1979), pdf.

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