Beyond "religious liberty"

Most of the attention given to the roiling legal fight over insurance coverage and birth control and the limits of religious exercise has come in the form of arguments about "religious liberty."

It is an issue of religious liberty, of course, though the tendency has been for those arguments to obscure more than they reveal. An example of this is Mike Huckabee's advocation for the craft store Hobby Lobby last month. Huckabee encouraged people to shop at the chain in an act of solidarity, a consumption-as-politics act of activism. He said:

They are having to fight in court for the most basic American rights of freedom of religion and freedom of speech .... The Obama administration insists that companies like Hobby Lobby bow their knees to the God of government health care mandates, even when those mandates are a clear and direct contradiction to their personal beliefs of faith.

The conflation that he's making here, between the corporation, Hobby Lobby, and "their personal beliefs of faith," is exactly what's at issue in these lawsuits. The grammatical issue of replacing a singular noun with a plural pronouns isn't an accident; it's the point. In promoting the identification of an individual shopper with the company, Huckabee's not actually making an argument that for-profit corporations can have religion and have the right to exercise religion, but re-casting the issue as a conflict between those who are for and those who are against religious freedom.

For the most part, though, it seems that the people most concerned with these legal battles are only concerned contingent on this confusion.

So it's interesting to see two conservative Christian media outlets approach the Hobby Lobby et al legal battles with Obamacare's HHS contraceptives coverage mandate from a very different direction. This last week, there were two articles where the lawsuits were put into a very different context.



At Christianity Today, journalist Melissa Steffan connected the legal cases to the pro-life movement. She wrote:

The battle over the mandate—and the emergency contraception it requires—has long been over personhood. Is a fertilized egg a person? Do the emergency contraceptives stop eggs from uterine implantation, ending a person's life?  

But now the legal battles against the HHS employer contraceptive mandate are shifting to very different questions of personhood: Are for-profit corporations "persons" in such a legal sense that they have religious rights? And do their religious liberties allow them to avoid the mandate?

Steffan doesn't try to articulate what the connection between those two arguments about personhood might actually be. The people she quotes -- mostly advocates for the companies suing the Obama administration -- don't approach that question either. The question is only raised, and pointed at.

It's a really interesting incongruity, though. Are the people who are dedicated to the idea that life begins at conception comfortable with this expansion of the definition of "person" to include corporations? Is this merely a pragmatic tactic, or is there an underlying philosophical connection between these two arguments about personhood?

At First Things, meanwhile, a professor from Pepperdine approached these lawsuits by connecting them to arguments about Sharia law in America.

Michael A. Helfand wrote:

The more religion has gone commercial, the more difficult it has become for courts to figure out how to treat conduct that that is simultaneously religious and commercial. Of course, these constitutional skirmishes are part of a far larger infrastructure of religious commerce. 

Notable examples include Sharia-compliant financial instruments and Jewish heter iska agreements, both of which are mechanisms for restructuring loans so as to avoid Islamic and Jewish law’s respective anti-usury rules. Religious communities have embraced contracts that use commercial forms to govern and structure a variety of religious relationships, such as employment contracts, arbitration provisions, and prenuptial agreements.

I don't entirely follow Helfand's line of reasoning. If I read him right, he's pivoting off of these lawsuits to make the case that religious laws have a place in American jurisprudence. His conclusion is that,

the best way to prevent the potential negative impact of religious law is to encourage ingenuity and creativity precisely at the nexus of religion and commerce. So long as courts continue to ensure that parties enter such agreements out of their own volition, the sophisticated drafting of agreements and structuring of relationships can provide solutions to the most worrisome religious customs and practices. Those supporting initiatives that hope to disaggregate religion and commerce miss the core insight that commercializing religion isn’t the problem: It’s the solution.

What this has to do with Hobby Lobby and other for-profit corporations opposed to insurance plans that cover employees' contraceptives, I'm not sure. It's interesting, though, to see the several emerging alternative rubrics for thinking about these legal cases besides arguments about "religious liberty."

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Francis Schaeffer and the death of Baby Doe

Francis Schaeffer's 1982 message to the Presbyterians at Coral Ridge Presbyterian Church in Fort Lauderdale, Fla., was pretty simple: the philosophy of modern society is humanism, and humanism means death.

The speech was part of Schaeffer's book tour for A Christian Manifesto, which had been published the year before. That book and tour, along with 1976's book and film series How Shall We Then Live? and 1979's book and film Whatever Happened to the Human Race?, all made a sustained argument about the need for Christian activism. The pro-life movement, as such, can be traced to these arguments; the religious right as a "bloc" and a single, mobilized, political entity, was formed in part by these efforts. Schaeffer made the historical and philosophical case that undergirded the emerging movement.

The argument was about attitudes towards life and death.

Attitudes exemplified by the issue of infanticide.

The case Schaeffer made to the Presbyterians hinged on claims about infanticide, its prevalence and its popular acceptability. His philosophical critique of modern America and his proscriptive solution of Christian action both depended on the accuracy of his cultural analysis. Both were dependent on the question of whether or not Schaeffer was right about the way the world was at that moment. For that reason alone, it's worth inquiring into the question of infants killed by doctors in 1982.

The answer to the question of whether or not Schaeffer was right about infanticide in 1982 will go some ways towards answering the questions of whether or not he was right about the modern world, and right or not about humanism.

Schaeffer's abstract, philosophical critique was a critique of humanism. This is constant throughout his work, and was essential to the point he was making in February 1982.

Schaeffer told the people at Coral Ridge:

What we are facing is Humanism: Man, the measure of all things -- viewing final reality being only material or energy shaped by chance -- therefore, human life having no intrinsic value -- therefore, the keeping of any individual life or any groups of human life, being purely an arbitrary choice by society at the given moment.

This is not an obvious argument. Humanism, as articulated in the two Humanist Manifestoes, explicitly and adamantly affirms the value of human life. The first Humanist Manifesto, written in 1933, concludes with the claim that humanism will "affirm life rather than deny it." The second Humanist Manifesto, written in '73, states that "the preciousness and dignity of the individual person is a central humanist value." Schaeffer is claiming that the humanists are wrong about what humanists believe. Or, more precisely, that they misunderstand the logical consequences of consistently holding to their humanist epistemology and ontology. They don't see the contradiction between denying God and excluding revelation and the supernatural from conversations about public policies, on the one hand, and upholding the value of human life on the other. For Schaeffer, the humanists may say that human life has value but they can't say it is intrinsically valuable, and that makes all the difference.

This is not just an abstract claim, though. Schaeffer was making an argument about what was actually happening in American at that moment. He claimed that this social development was visible: Humanism has taken over and has wrought death.

As evidence of this, he offered the current practice of doctors and nurses committing infanticide. Those who looked, he said, would see how humanism, in practice, meant the devaluation of human life:

Believe me, it's everywhere. It isn't just abortion. It's infanticide. It's allowing the babies to starve to death after they are born. If they do not come up to some doctor's concept of a quality of life worth living. I'll just say in passing -- and never forget it -- it takes about 15 days, often, for these babies to starve to death....

So what we find then, is that the medical profession has largely changed -- not all doctors. I'm sure there are doctors here in the audience who feel very, very differently, who feel indeed that human life is important and you wouldn't take it, easily, wantonly. But, in general, we must say (and all you have to do is look at the TV programs), all you have to do is hear about the increased talk about allowing the Mongoloid child -- the child with Down's Syndrome -- to starve to death if it's born this way. Increasingly, we find on every side the medical profession has changed its views. The view now is, "Is this life worth saving?"

This is not a philosophical claim. It's a claim, rather, about what was actually happening in 1982, and should be a matter of record, a claim that could be verified. Where arguments about what humanists "really" believe are not likely to go anywhere, it should be a simple enough matter to establish whether or not Schaeffer was right about what was happening in American hospitals in 1982. Note that he was not here making a slippery slope argument, saying that the legalization of abortion will at some future date end up meaning that infanticide is an accepted practice. That's common in pro-life rhetoric, and Schaeffer made that argument too, but that's not what Schaeffer was saying here. He was making the claim that there was a general practice in the medical profession -- i.e., an implementation of humanism -- such that certain sorts of infants were being starved to death.

Is this true?

Were newborns being regularly killed in American hospitals -- easily, wantonly, and so on?

No.

There's one particularly famous case from that same year that would seem, on one level, to confirm what Schaeffer argued. An infant born with Down's syndrome was allowed to starve to death in a hospital in Bloomington, Indiana, in 1982, two months after Schaeffer's Florida speech. Some of the basic facts might seem to confirm his claims, but the details of that case show that Schaeffer was wrong -- importantly -- about the majority attitudes towards life and death in American hospitals. The full story of the Baby Doe case, as it's called, seriously undermine Schaeffer's argument.

Here's what happened: a child was born on Good Friday, April 1982. He was born with Down's syndrome and a disorder of the digestive system, esophageal atresia. This meant he could not eat.

There were three doctors in the case. Two recommended transporting the infant immediately to another hospital where emergency surgery could be preformed. The surgery had a 90 percent chance of success. The third -- the doctor who actually delivered the child -- said that there was another option that the parents had to consider.

They could let their child die.

The third doctor, Walter Owens, said the surgery would be painful, and possibly only the first of many, and the child would still have Down's. He suspected there were also other issues, such as brain damage. He said the child would be a "mere blob." They had a choice and they needed to know they had a choice that they had to make.

The family, which had had experiences with children with Down's, decided to let their child die. Owens told them they were being courageous, and said, "Here's how I look at it. If you let the baby die, you're going to grieve a little while. But if you go ahead with this surgery, you're going to grieve for the rest of your lives."

To this point, the story seems to align exactly with what Schaeffer predicted. Owens was a Unitarian-Universalist, incidentally, which would also fit Schaeffer's cultural analysis of the betrayal of Reformed Christian worldview and its consequences.

The story goes on, however. One of the doctors recommending the emergency surgery -- who happened to be named Schaffer -- fought for the infant's life. He appealed to the hospital authorities, and they brought in a judge on Saturday night to make a decision about this case. According to Jeff Lyons, who wrote the history of the Baby Doe case (1, 2, 3, 4), the judge was at home coloring Easter eggs with his children when the call came, and there was an emergency hearing at the hospital.

Lyons writes:

At issue was nothing less than whether parents ever have the right to refuse live-saving treatment for their children and whether a life of handicap is so abysmal as to warrant its termination at birth. 

Only rarely in American jurisprudence had such questions been raised. On the few occasions on which they had, the courts had almost invariably ruled against the parents and in favor of life. But in those instances the doctors had always been lined up against the parents. 

In Bloomington, however, it was a different matter. There existed a strong--one might say vehement--difference of clinical opinion as to what the best course of treatment was.

After hearing the evidence and the testimony of the conflicting doctors, as well as the arguments of the hospital's lawyers and a cleric, the judge took 30 minutes to deliberate. Then he ruled that it was not the court's place to make this decision: when a family is presented with two options by medical professionals, it is their right to make the choice about which course of action to take concerning a newborn infant. The family in this case had made their decision, and the child would die.

That wasn't the end of it, though.

The nurses revolted. A sign was taped to Baby Doe's crib saying "Do Not Feed." Possibly this was because of the problem with the infant's esophagus, but it was taken as a symbol of the parent's decision to starve their child. The head nurse saw the sign and responded: "Over my dead body." En masse, the nurses threatened to strike.

Francis Schaeffer, from a certain perspective, seems prescient here. At Coral Ridge, two months before, he had said that nurses would be asked to participate in the death of infants. He predicted there would be signs on cribs that said "Do Not Feed," and that nurses would be fired if they refused to follow those orders. The nurses in Bloomington did refuse, though, and they weren't fired. The hospital took their side. Instead of firing the nurses, the child was moved out of the nursery, taken to another floor, and the family was required to hire private nurses.

There was also immediate, fierce criticism of the judge, and so the decision was referred to the state's Child Protection Committee, with a guardian appointed to represent the interests of the child in that hearing. After 45 minutes of deliberation, Lyons reports, the committee returned with the same decision, affirming the rights of the parent's to make this medical decision.

Neither the court nor the committee, it's worth noting, never made any sort of decision about the value of the infant's life, or about the ways in which, perhaps, quality of life could be measured against life itself. Rather, they considered and made a ruling about who has the right to the final decision about how to respond to an infant's serious medical condition when doctors disagree. They decided, very conservatively, that the state does not have the power, nor does the hospital. The rights are the parents', in consultation with their physicians.

There was another legal challenge the next day, when the county prosecutor tried to have the child declared neglected, giving the state the authority to overrule the parent's decision. That failed, and there were then a series of other efforts: a local attorney acting on behalf of the county prosecutor applied for a temporary restraining order agains the parents; a lawyer for the National Right to Life Association filed a petition on behalf of a couple that wanted to adopt Baby Doe; an appeal was made to the Indiana Supreme Court; plans were made to appeal to the Supreme Court.

All of these failed. Mostly for legal and technical reasons.

The parents, meanwhile, named the child Walter after Owens, the doctor who'd recommended they let him die. They had the infant baptized into the Catholic Church by their parish priest. They asked their nurses when the ordeal would be over.

Others continued to fight for the infant's life, nevertheless. Protestors gathered outside the hospital with signs. The doctor who strongly recommended the emergency surgery, Schaffer, tried to break into Baby Doe's room to administer an IV, to feed the dying child. Lyon's calls it "one of the most bizarre episodes in the history of American medicine, an episode that saw one doctor guard a dying baby from another doctor who was threatening to try and save its life." The rescue mission only stopped because it was too late. The doctor said he knew that feeding the dying infant intravenously could cost him his medical license or even result in criminal charges of kidnapping. But he didn't care. It was too late, though.

At six days old, denied medical treatment and denied food, Baby Doe died.

There don't seem to be any reliable figures to indicate how many similar cases occurred in the United States in 1982. It's just not known if, as Schaeffer said, such practices were "everywhere." The fact that this case received such attention, though, and evoked such a strong response, suggests that letting Down's children or otherwise handicapped children die was not common or commonly accepted. A similar case in 1983 received similar attention, and similarly garnered outrage from the public, the medical community and legal community, indicating that while there were some doctors doing this sort of thing, they faced overwhelming resistance.

Schaeffer's description of the culture, where "the medical profession has largely changed," is simply factually wrong.

But what should be made of this? It seems significant that he was wrong. Schaeffer's cultural analysis and his philosophical analysis in this 1982 speech depended very much on the truth of the claim that infanticide was happening, and happening without any resistance. The entire argument that he made in Fort Lauderdale, Fla., can be summed up with these two arguments that both rest on this purported fact of infanticide: modern society is humanist, humanism results in the devaluation of life, and thus the modern world is now a place where infants with Down's are being nonchalantly killed.

But they weren't, though. Not nonchalantly.

According to reports, even in such liberal quarters as the Washington Post, Baby Doe's death was considered a tragedy. The American Academy of Pediatrics expressed "open concern that Baby Does' obstetric physician had made a mistake, that poor advice was given to the family and that such an event should be avoided." An article published in the Western Journal of Medicine said the doctor made a "serious judgement error," because of his own prejudice and bias. The next year, in response to the public outcry, every hospital that received federal funding was required to prominently post signs announcing "discriminatory failure to feed and care for handicapped infants ... is prohibited by federal law." Several laws were passed, following the case. Reflecting on the case 20 years later, the judge who'd been called to the Bloomington hospital on Easter eve noted that "if this situation had happened in present-day courts, there would be no doubt all action would have been taken to save the baby's life because of new state and federal laws that prohibit such acts."

If Walter Owens received any support in this case, for his opinion that the child should be allowed to die, it wasn't very vocal. Even those who opposed the Baby Doe regulations went out of their way to make it clear that they thought the doctor made a horrible decision.

All of this points to the fact that Schaeffer was wrong. The reaction to the Baby Doe case shows that the America of 1982 was not the kind of place that Francis Schaeffer thought it was. While there may have been a few who, in specific cases, asked the question, "Is this life worth saving?," that was clearly not happening "on every side." When you look at what actually was the case, what you find is the opposite of what Schaeffer said would be found. People overwhelmingly wanted to keep this infant alive, and valued his life enough to try to get the government to take away the parents' legal rights.

Schaeffer's message, to Coral Ridge Presbyterian Church and in those tours in 1976, '79 and '82, was about the dangers of humanism, and how Christians should wake up because humanism had taken over their world, reshaped their country, and put the lives of America's most vulnerable in jeopardy. In this specific instance, he made very concrete claims about how that was happening, but it's clear he was wrong.

Schaeffer's cultural analysis was mistaken.

The only possible conclusions, it seems, is that either he was wrong about humanism having taken over America, or, alternatively, it's just not the case that humanism devalues human life in the way Schaeffer said it did.

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'This right of privacy . . . is broad enough to encompass a woman's decision whether or not to terminate her pregnancy'

Roe vs. Wade, the federal case that legalized abortion, thus determining one critical line of political battle and cultural division for generations to come, was handed down by the Supreme Court 40 years ago today.

The decision, writing by Justice Harry Blackmun, focused on the question of whether privacy was a right guaranteed by the constitution. That's not normally the core of the debate as it's debated day to day in American culture, but that was the central question of the legal issue.

A key excerpt of the decision, on the matter of a constitutional right to privacy:

The Constitution does not explicitly mention any right of privacy. In a line of decisions, however, going back perhaps as far as Union Pacific R. Co. v. Botsford, (1891), the Court has recognized that a right of personal privacy, or a guarantee of certain areas or zones of privacy, does exist under the Constitution. In varying contexts, the Court or individual Justices have, indeed, found at least the roots of that right in the First Amendment, Stanley v. Georgia, (1969); in the Fourth and Fifth Amendments, Terry v. Ohio, (1968), Katz v. United States, (1967), Boyd v. United States, (1886), see Olmstead v. United States, (1928) (Brandeis, J., dissenting); in the penumbras of the Bill of Rights, Griswold v. Connecticut, ; in the Ninth Amendment, (Goldberg, J., concurring); or in the concept of liberty guaranteed by the first section of the Fourteenth Amendment, see Meyer v. Nebraska, (1923). These decisions make it clear that only personal rights that can be deemed "fundamental" or "implicit in the concept of ordered liberty," Palko v. Connecticut, (1937), are included in this guarantee of personal privacy. They also make it clear that the right has some extension to activities relating to marriage, Loving v. Virginia, (1967); procreation, Skinner v. Oklahoma, (1942); contraception, Eisenstadt v. Baird, (WHITE, J., concurring in result); family relationships, Prince v. Massachusetts, (1944); and child rearing and education, Pierce v. Society of Sisters, (1925), Meyer v. Nebraska, supra.

This right of privacy, whether it be founded in the Fourteenth Amendment's concept of personal liberty and restrictions upon state action, as we feel it is, or, as the District Court determined, in the Ninth Amendment's reservation of rights to the people, is broad enough to encompass a woman's decision whether or not to terminate her pregnancy. The detriment that the State would impose upon the pregnant woman by denying this choice altogether is apparent. Specific and direct harm medically diagnosable even in early pregnancy may be involved. Maternity, or additional offspring, may force upon the woman a distressful life and future. Psychological harm may be imminent. Mental and physical health may be taxed by child care. There is also the distress, for all concerned, associated with the unwanted child, and there is the problem of bringing a child into a family already unable, psychologically and otherwise, to care for it. In other cases, as in this one, the additional difficulties and continuing stigma of unwed motherhood may be involved. All these are factors the woman and her responsible physician necessarily will consider in consultation.

On the basis of elements such as these, appellant and some amici argue that the woman'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. Appellant's arguments that Texas either has no valid interest at all in regulating the abortion decision, or no interest strong enough to support any limitation upon the woman's sole determination, are unpersuasive. The Court's decisions recognizing a right of privacy also acknowledge that some state regulation in areas protected by that right is appropriate. As noted above, a State may properly assert important interests in safeguarding health, in maintaining medical standards, and in protecting potential life. At some point in pregnancy, these respective interests become sufficiently compelling to sustain regulation of the factors that govern the abortion decision. The privacy right involved, therefore, cannot be said to be absolute. In fact, it is not clear to us that the claim asserted by some amici that one has an unlimited right to do with one's body as one pleases bears a close relationship to the right of privacy previously articulated in the Court's decisions. The Court has refused to recognize an unlimited right of this kind in the past. Jacobson v. Massachusetts, (1905) (vaccination); Buck v. Bell, (1927) (sterilization).

We, therefore, conclude that the right of personal privacy includes the abortion decision, but that this right is not unqualified and must be considered against important state interests in regulation.

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Some facts about women who have had abortions. Tomorrow marks the 40th anniversary of the supreme court decision that legalized abortion in the United States. 

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A political 'evolution' on social conservative issues

Has Mitt Romney evolved?

According to the conservative Christian group Family Research Council, Romney has changed positions on five key issues between the Republican primaries and the general election. Contrary to the conventional wisdom that says candidates tack to the center during general elections, and become more moderate to appeal to independents and swing voters, Romney has apparently strengthened his case with social conservatives since winning the Republican party nomination.

Where once he was squishy, apparently, on the issues the FRC cared about, now he's firm. Where once the FRC judged the Mass. governor to be only 50 percent in line with the positions of "values voters," he now has a perfect score.

Of course it's possible it's not Romney who has changed.

As noted by Christianity Today in a piece on Christian voter guides last week, the FRC guide released during the primaries highlighted significant areas of disagreement with Romney: stem cell research, cloning, the estate tax, employee non-discrimination, and "strict constitutionalist" judges. On half the issues held to be important by the conservative group started by evangelical child-rearing guru James Dobson, Romney was represented as being on the wrong side.

That voting guide showed him to be a less desirable candidate than Michele Bachmann, Rick Santorum, or Rick Perry. Newt Gingrich and Ron Paul didn't have perfect scores -- both differing from the FRC on the question of a federal ban on human cloning -- but they still were more in line with the group's position than Romney.

Correction: than Romney was.

According to the FRC voting guide being distributed right now as church bulletin inserts, Romney has changed his position on all five of these issues, and is now in complete agreement with the conservative Christian positions on everything that's politically important.

In at least one case, though, Romney has managed this remarkable transformation without actually changing his position. The FRC footnotes their sources for the statements about candidates' positions, and though the earlier guide and the later guide represent Romney as having different positions on stem cell research, the sources cited say the same thing in both cases. He's for stem cell research, but opposed to embryos created specifically for such studies, and opposed to federal funding of these studies.

As Romney himself explained the position in 2007, "There are different levels of stem cell research."

That nuanced position was presented by the FRC as having a "mixed" record on the issue. It is now being presented as opposing the federal funding of stem cell research, which is true, but has actually always been Romney's position. His statements on the issue, cited by the FRC, are consistent from 2005 to today. It's the FRC's representation of that position has changed.

So perhaps it's the Family Research Council that has evolved?

In another case, the records cited by the FRC show Romney has in fact changed his position, but that change happened long before either voting guide was published. Romney's current position on federal protection of gays and lesbians against employer discrimination has been represented in two diametrically opposite ways.

It's true that in 1994 Romney pledged his support for EDNA, the "Employment Non-Discrimination Act" that the FRC calls "SPECIAL EMPLOYMENT RIGHTS BASED ON SEXUAL BEHAVIOR." Romney instituted a non-discrimination policy that included sexual orientation as one of the protected classes when he was organizing the hosting of the 2002 Olympics. In 2007, though, Romney announced that he'd adjusted his position, and now felt that protecting people from discrimination was the states' job, not the federal government's. He told Tim Russert, "I think it makes sense at the state level for states to put in provision of this .... I would not support at the federal level, and I changed in that regard because I think that policy makes more sense to be evaluated or to be implemented at the state level."

During the primaries, that 2007 position was characterized by the FRC as support for the Employment Non-Discrimination Act." That same position is now characterized by the FRC as opposition.

The word for this is duplicitous.

Much has been made of Romney's inconsistencies and how his only guiding principle seems to be his own desire for power. Especially when it comes to the social issues that concern conservative Christians. That, it turns out, may not be a problem for those who claim to represent these Christians, but rather a key a point of commonality.

The FRC voting guides show that Romney has strengthened his position with at least some conservative Christian groups -- but only because they too are more committed to political victories than anything else.

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Obamacare prevents abortions

A new study suggests that the Affordable Care Act, i.e., "Obamacare," may be "the single most effective piece of 'pro-life' legislation in the past forty years," reducing abortions by up to 78 percent (!). The study tested the effects of Obamacare by covering the costs of birth control -- particularly more expensive but more effective methods -- for poor and currently uninsured or under-insured women.

The results:

"Between 2008 and 2010, abortion rates in CHOICE [study] participants ranged from 4.4 to 7.5 per 1,000 after adjusting for age and race. These rates are considerably less than the rates in St. Louis City and County for the same years and far below the national rate of 19.6 per 1,000. Using these data, we then estimated the difference in abortion rates and number of abortions prevented each year if CHOICE were available to the entire population of the region. Based on the number needed to treat, one abortion could be prevented for every 79–137 women and teenagers provided the CHOICE intervention.

".... changes in contraceptive policy simulating the Contraceptive CHOICE Project would prevent as many as 62–78% of abortions performed annually in the United States."

In the first year of the study, providing birth control for more than 9,000 women prevented an estimated 3,000 pregnancies that would have likely resulted in abortions. In comparison to women from the surrounding area in the same socio-economic bracket, the number of abortions in subsequent years was reduced by nearly 2,000 per year.

The study -- done by Jeffrey F. Peipert, Tessa Madden, Jenifer E. Allsworth and Gina M. Secura at the Washington University School of Medicine --  concludes that this is a "a clinically and statistically significant reduction in abortion rates," supporting the idea that "Unintended pregnancies may be reduced by providing no-cost contraception and promoting the most effective contraceptive methods."

Providing "no-cost contraception" is exactly what Obamacare would do, if not gutted or repealed by Republicans.

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