Duress Rebuttal: A Rebuttal to the Strategy of Duress Provisions for Prenatal Murder
Introduction
This response addresses sections from the Foundation to Abolish Abortion article “Understanding Duress Provisions in Prenatal Equal Protection Legislation.” The premise of my opposition to duress as a defense for prenatal murder is that biblical ethics, church tradition and historic American legal principles affirm that what is done with malice aforethought to an innocent image-bearer is never justifiable, even under threat, coercion or duress. Such a defense undermines both moral accountability of the guilty and scriptural requirements of the magistrates and should not be incorporated into abolition legislation in states that do not already allow for such a defense against murder. For the few states that do allow duress as a defense to murder, I believe Christians should seek to remove that defense from homicide law since it conflicts with scripture. At the same time, any equal justice bill that is written and supported by Christians should not include a duress defense in it, as it is against the biblical standard of justice. Such efforts could potentially be a separate initiative from equal protection and justice bills for prenatal children.
Therefore, this dissenting rejoinder examines the moral and legal consequences of extending a duress defense for prenatal homicide. The following subtitles are sections from the FAA article with my corresponding rebuttal and thoughts listed below.
A. Hidden Moral Test: The Duress ‘Dilemma’
“...someone ‘ought rather to die himself, than escape by the murder of an innocent.’ However, the rationale for this exception is always discussed in the context of born persons. But does it apply in the same way when the person killed was inside the body of the one being threatened? …”
1.1. Biblical Stratification of Homicide
Scripture divides homicide into three categories: murder, manslaughter and self-defense. The one who purposely kills innocent human life must be put to death (Gen. 9:6), the manslayer can redeem his own life if he flees to a city of refuge (Num. 35:11-12), and the self-defendant is justified before God since the life of the wicked person was reckoned for by his own blood (Ex. 22:2-3). We see these principles laid out within our own homicide statutes by holding premeditated murderers to the highest prosecution standard, accounting for the manslayer with reduced sentencing, and establishing Castle Doctrine and self-defense law that require proof of imminent threat, proportional force, and reasonable fear—showing the person genuinely believed they or another innocent person were in immediate danger of being a murder victim and acted to prevent it. In the latter case, scripture’s requirement of bloodguilt (Num. 35:33, “...blood pollutes the land, and no atonement can be made...except by the blood of the one who shed it.”) is fulfilled by taking the life of the one guilty of premeditating the destruction of another Image Bearer. The bloodguilt is transferred from the self-defendant to the perpetrator and immediate justice is satisfied. It’s because of these principles that common law has never recognized duress as a defense for murder.
1.2. Historical Church Conviction
Today Christians recognize the general equity of the moral and civil law given to Moses. General equity allows today for different judicial punishments for crimes other than what was allotted in ancient Israel under Mosaic Law, but capital punishment for murder is a creation mandate given to all humanity (Gen. 9:6). It does not fall within the general equity sphere. If the creation mandate of capital punishment for murder with malice aforethrough can be altered, what other creation mandates can we also revise (marriage between a man and woman; dominion of the earth; procreation; criminal punishments referred to by Christ in Matt. 5:19)?
Because of this, I believe our approach to the crime of murder must be categorically different from other crimes such as robbery, battery, kidnapping, adultery, etc. In fact, allowing for lessened sentencing for non-murder crimes can be biblically true at the same time that not allowing for lessened sentencing for murder cases can be true. In formal logic, they are independent statements.
1.3. Common Law and The Jurists
1.3.1. William Blackstone
The FAA article references Justice William Blackstone as saying, “Though a person be violently assaulted, and has no other possible means of escaping death but by killing an innocent person; this fear and force shall not acquit him of murder; for he ought rather to die himself, than escape by the murder of an innocent.”
Blackstone further makes the distinction that self-defense needs to be carefully guarded so that someone doesn’t cross over into the place of the assailant: “Self-defence…is justly called the primary law of nature…In the English law particularly it is held an excuse for breaches of the peace, nay even for homicide itself: but care must be taken, that the resistance does not exceed the bounds of mere defence and prevention; for then the defender would himself become an aggressor."1
1.3.2. Samuel von Pufendorf
Samuel von Pufendorf, a 17th-century jurist, likewise wrote: "To Self-Preservation...belongs Self-Defence, or the warding off such Evils or Mischiefs as tend to our hurt, when offer'd by other Men. This Defence of our selves may be undertaken two ways, either without hurting him, who designs the Mischief against us; or else by hurting or destroying him…. So that if another Man make an Attempt upon my Life, there is no Law that commands me to forgo my own Safety, so that he may practice his Malice with immunity. And he that in such case is hurt or slain, must impute his Mischief to his own Wickedness, which set me under a Necessity of doing what I did.”2
Both men, along with scripture, recognized that lethal force to protect yourself is justified when directed toward the one threatening you. Common law, which heralds to scripture as its inspiration, doesn’t recognize murdering another innocent person under personal threat of harm as valid because aggression is used against an innocent bystander and not properly directed toward the malicious instigator. Consequently, acting with lethal force against an innocent person while under personal threat of harm does not mitigate the crime but perpetuates it. Now two actors, instead of just one, are intent on harming another innocent life for personal gain.
Even under threat of harm to oneself, taking the life of another innocent person destroys the innocence of the one initially threatened. Blackstone would agree that the defender has become the aggressor. And this is what takes place when a duress defense is given to a pregnant woman who commits prenatal murder. The crime hasn’t changed; just the principal actor.
1.3.3. Wayne LaFave
Following the Blackstone quote, legal scholar Wayne LaFave is quoted in the FAA article as supporting duress as a defense to murder if it helps save lives:
“Setting aside his discussion of the excuse still applying where more than one person would be saved or where B played a minor part, the very first part of LaFave’s comment is instructive. Under ordinary circumstances, the rationale behind why person C should not be entitled to the duress excuse in an intentional homicide situation is because person C is a person “who would otherwise be safe” in the event B were killed…this is not true in the case of a preborn child. In the case of a pregnant mother, if the mother is threatened with death if she does not kill her preborn child, and if she is killed after resisting the duress, the preborn child would not “otherwise be safe.” Both would die. This is because the life of the mother is physiologically connected with the life of the child. The life of the child is dependent upon the life of the mother in a unique way that does not exist in other circumstances.”3
The FAA article argues that allowing duress as a defense in prenatal murder is acceptable only because the baby would die anyway if the instigator followed through with his or her threat against the mother. It's implied this is a way in which to preserve the most lives possible by giving the woman a way out legally for her crime that she otherwise would not have committed.
1.4. Comparison and Conclusion
I would argue that the most important virtue is not saving the most lives but innocence before God. The pro-life paradigm teaches it is permissible to save as many lives as possible at the expense of faithfulness to God, yet Martin Luther famously proclaimed, “My conscience is captive to the Word of God.” What God says on an issue is our ultimate plumb line.
Compared to LaFave, Blackstone’s position is superior when he says one “ought rather to die himself, than escape by the murder of an innocent.” A pregnant woman ought rather to die a victim alongside her child than be guilty before God as her child’s murderer. Our laws should point toward this moral reality.
B. Duress As Excuse in Murder?
“... what you did was wrong, but the circumstances make it inappropriate to hold you fully accountable.”
2.1. Biblical Precedent for Duress
We know from scripture that the highest calling is to lay down our lives for another (John 15:13) and that women who turn against their own children is a sign of God’s judgment (Lam. 4:10; 2 Kings 6:28-29) because it is so unnatural (Isa. 49:15). The one biblical instance we have of women put under duress to commit murder concludes with God blessing them because they did not succumb to saving their own lives at the expense of the children's:
“Then the king of Egypt said to the Hebrew midwives, one of whom was named Shiphrah and the other Puah, “When you serve as midwife to the Hebrew women and see them on the birthstool, if it is a son, you shall kill him, but if it is a daughter, she shall live. But the midwives feared God and did not do as the king of Egypt commanded them, but let the male children live. So the king of Egypt called the midwives and said to them, “Why have you done this, and let the male children live?” The midwives said to Pharaoh, “Because the Hebrew women are not like the Egyptian women, for they are vigorous and give birth before the midwife comes to them.” So God dealt well with the midwives. And the people multiplied and grew very strong. And because the midwives feared God, he gave them families.” – Ex. 1:15-21
God blessed the midwives' obedience and gave them fruitful families because they didn't cut off the lineage of other families in order to save themselves. They cared more about being innocent before God than being safe from pharaoh.
2.2. Historical Church Conviction
A duress defense for the pregnant woman to save her life by the sacrifice of her child's life is a gross violation of natural affection and contrary to the actions of the Israelite midwives. John Calvin commented on Exodus 21: “If it seems more horrible to kill a man in his own house than in a field, because a man's house is his most secure place of refuge, it ought surely to be deemed more atrocious to destroy a fetus in the womb before it has come to light.”4
Calvin was addressing the atrocity of lost prenatal life from two men fighting and accidentally causing the death of a prenatal child. If accidental death from a third party was deplorable to Calvin, what would he have to say of a mother who causes her child’s death purposefully under moral pressure to save her own skin?
Even though the mother is being victimized by an aggressor, she has a choice to make: Lay down her life as a victim; fight back in self-defense; attempt to summon help; or turn as an aggressor against her child. Only three of those are permissible before God. The latter makes her guilty or murder both biblically and legally. As such, it is highly appropriate to hold her fully accountable if she chooses the fourth option.
C. Legal Technicalities: Temptation or Excuse?
“... a legal excuse just means that the defendant is not held responsible for their wrongful actions due to circumstances that significantly impaired their moral or legal culpability.”
A legal excuse for a pregnant woman doesn’t prevent the act of prenatal murder but excuses the biblically guilty person. It may even encourage the use of such accusations in a post-Roe culture. The duress position concedes that since there is nothing that can be done to save the child due to its location, murderous intent can be excused in the mother. This seems yet another pro-life “life of the mother” exception.
Scripture doesn’t provide special circumstances to harm an innocent image bearer based on their proximity to another victim. And the Bible routinely recognizes maternal harm to her child as among the severest depravity or due to “impaired culpability.” Murder under duress is a moral temptation, not a legal excuse.
Consequently, if a prenatal child’s biological dependency on his mother allows the mother to choose to end that child’s life to preserve her own, then the same logic seems to permit—or even require—the permissibility of abortion in cases where the child is going to die anyway from fatal abnormalities or any physical threat to the mother’s health (going even past the ectopic issue).
This “life of the mother” justification rests on the premise that a mother has a greater legal and moral right to life than her child due to self-preservation, and the biological dependency of the child justifies her actions against that child’s life. It can be argued that “life of the mother” reasoning is being applied in favor of duress as a defense to prenatal murder. Legally, this reasoning takes away the right to self-preservation from the child in favor of a "higher/superior" right to life of the mother. Once this precedent is established, what would stop a savvy legal mind from justifying other instances of prenatal murder in the name of other “health” or “safety” threats? Duress undermines our opposition to prenatal murder.
Abolitionists reject the imminent death justification for killing people because we recognize it’s in opposition to God’s law and would logically transcend the abortion issue: every hospice patient and neonatal ICU infant would suddenly be vulnerable. May the law excuse us before God and man if we deliberately end the life of someone who isn’t expected to make it anyway? Traditionally, Christians do not allow that reasoning postnatally and we should reject it prenatally as well. Furthermore, this puts the focus and weight of the duress argument on the prenatal child’s location and viability: the very things we accuse the Pro-Life Movement of doing.
A duress defense legitimizes arbitrary thresholds for determining the guilt of a mother who premeditates the killing of her prenatal child. Heartbeat bills excuse mothers who kill their children before six weeks of gestation; a viability standard exempts mothers who slaughter their babies before life-sustaining NICU capabilities; and a duress defense absolves mothers who sacrifice their child’s life in the name of self-preservation.
While the FAA article points out the biological truth of pregnancy that “The life of the child is dependent upon the life of the mother in a unique way that does not exist in other circumstances,” I don’t believe that negates biblical principle. Biology is still subservient to morality. God says thou shalt not murder … even under threat of harm to oneself. May we actually excuse this?
D. The ‘Desperate’ Choice
“... the mother may commit the act of homicide—taking the abortion pill—with the hope that the person putting her under duress will leave.”
It defies logic for an instigator to make such a blatant, open threat against a woman and her unborn child when he could quietly slip the pill into her drink and claim it was a miscarriage. But assuming for a moment this duress situation would exist, people cannot engage in wicked behavior in the hopes of escaping personal trouble and then try to undo the damage they did to someone else in that pursuit. Matthew 7:16 says, “By their fruits you shall know them.” True resistance to evil should be proven by a person willing to suffer for doing right, not by engaging in evil choices that they hope to reverse later. No one should do evil in order that good may come (Romans 3:8).
The FAA article enumerates three conditions to establish duress: 1) immediate threat; 2) reasonable fear; and 3) no reasonable escape. To substantiate, it cites Manual of Model Criminal Jury Instructions for the District Courts of the Ninth Circuit, 2022 Edition. The article suggests there is a difference in timing and circumstances between a surgical and medication abortion, which warrants the use of duress for one over the other:
“In a surgical abortion situation, the mother likely has many opportunities to escape because the abortion is taking place at a clinic or hospital, away from the person doing the threatening. So because she has reasonable opportunities to escape, the duress defense would not apply.”
However, the Manual also establishes that "duress is not a defense to murder, nor will it mitigate murder to manslaughter” by citing United States v. LaFleur. Legally there is no justification for a duress plea for surgical abortion or the abortion pill. In addition to overlooking biblical principles that should be applied to both types of prenatal murder methods, the FAA article makes an either-or fallacy by positing that if a gun is to a mother’s head she only has the option of either taking the pills or being murdered. In both surgical or medication abortions a woman has the choice to either participate, flee, contact authorities, fight back or refuse to comply. Scripture consistently teaches that righteous suffering is better than compromising with evil (Hebrews 11).
4.1. No Excuses: Guilty Mind and Guilty Act
Legally, regardless of what the woman’s intention was for the future after she committed a crime, she would still be found guilty of at least attempted murder under the criteria for mens rea (Latin for “guilty mind") and actus reus (Latin for "guilty act”).
Mens rea describes a criminal's state of mind at the time he or she transgressed the law. It must be proven that someone was aware of their misconduct and understood that their actions would lead to a violation of the law. If one argues that a mother lacked murderous intent for mens rea, she still demonstrates reckless regard for life by consuming poison, which is enough to convict someone of murder. But at the root she did intend to commit murder because that is the deal offered to her by the instigator – “kill this person or be killed yourself.”
Actus reus is the physical act of committing a crime. This is demonstrated by a mother's voluntary consumption of pills designed to kill a prenatal human. If she understands that the pills are intended to kill her unborn child and chooses to take them anyway, that would meet the standard for actus reus. Even if she doesn’t understand what abortion pills are before this event, I believe it would be fairly easy to prove that she gained the knowledge of what they are designed to do if they are being offered to her in order to abort her child.
The U.S. Justice Department defines murder as “the unlawful killing of a human being with malice aforethought.” This means intentionally taking the life of someone who has done nothing to deserve a death sentence. If a woman knowingly takes abortion pills that are intended to end the life of her preborn child, and she understands the likely outcome, her action fits the legal definition of a guilty act. To excuse mens rea and actus reus in a prenatal murder case is to explicitly ignore the law in favor of physiology. It also disregards two of the most foundational elements of the justice system by replacing it with at-her-word. Any woman can say she intended to save her child after she was in a safer place. But that's not how the courts handle born murder. We cannot justify this exception by biblical standards or existing legal standards for murder.
E. Duress and Partiality
“Extending the duress defense has nothing to do with partiality in judgment.”
Assuming for a moment that there is no partiality in extending the duress defense for murder to pregnant women, it’s still biblically wrong. Consider this section from the FAA article:
“Extending the duress defense has nothing to do with partiality in judgment--denying a person justice due to a bias or prejudice against them, or for someone else, based solely on the parties' identities. Instead, this has everything to do with taking the same principles underlying the current law and applying them to a different set of circumstances.Taking a view of equal protection that requires mechanistically identical treatment with absolutely no account for the underlying basis for the law would lead to absurd applications. For example, it is legal to shoot a person who is in the act of trying to kill another born human being. If we apply that to the situation of a preborn child in a mechanistically formulaic way, however, would this mean that it should be legal to shoot a woman who is 10 weeks pregnant who is in the act of taking an abortion pill, as long as you do not hit the baby? That would be absurd. And the reason it would be absurd is because of the unique circumstances of pregnancy: if the mother dies, the baby dies too.”
What makes it absurd to shoot a pregnant woman to stop her from murdering her prenatal child is that doing so would result in you now being the aggressor against the very child you're trying to save. Likewise, extending a duress defense to excuse abortion is absurd because it reduces the punishment for someone who, according to scripture, has unjustly taken a life and should face justice: “Whoever sheds the blood of man, by man shall his blood be shed” (Gen. 9:6). At the core, both actions violate God's commandments — “You shall not murder” and the principle of life for life. Therefore, both actions are wrong because they disobey God. The partiality claim is a secondary issue, though worth still addressing.
Partiality is demonstrated in that the baby is neglected equal justice against one of the main perpetrators against his or her life in favor of some "higher" legal principle of self-defense, which is unsubstantiated since it’s against an innocent victim. The same reasoning won't apply to a born person's murder. Why should it apply to a pre-born person's murder?
A gravid duress defense also prohibits similarly accused people from accessing the same type of defense or plea bargain that a pregnant woman would benefit from. The biological reality of pregnancy does not override the greater principle of moral accountability before God or impartial jurisprudence. Scripture makes no exceptions to the commandment against murder, even in cases of hardship. Bradley Pierce once said that under pro-life laws Lady Justice peeks under her blindfold to see if the victim is a prenatal child and the accused the mother before deciding if justice applies. Likewise, under the duress standard, Lady Justice lifts the blindfold to check if the killer was a pregnant woman before allowing a duress defense. This soundly demonstrates partiality.
Just as policies that excuse wrongdoing based on race or social background undermine equal justice (such as Affirmative Action), so too does legally excusing prenatal murder due to biological circumstances. Justice must be grounded in immutable moral law.
F. Duress in (Pre-born) Murder: A Judicial Revolution
“Duress is not something that a defendant can just make up after the fact. There must be evidence for the claim.”
It’s difficult to prove duress. And perhaps this is in mind when writing equal protection bills. However, calling it out specifically for pregnant women to use in states that don’t allow for it as a defense to born murder is setting a new judicial precedent in those states and showing favoritism to a special class of people. Who else in Kansas can use duress as a defense for murder under this standard? No one except a pregnant woman against her own prenatal child.
Most importantly, as established earlier, duress as a defense for murder is unbiblical and we should not seek to expand it in states that abide by common law as opposed to the post-modern American Law Institute’s Model Penal Code. It's been a historical position among Christians to take a hard-line on punishment for murder. Christians who have the law of God cannot let those who are fomenting a judicial revolution define our legal terms.
“An Abstract of the Laws of New England”, penned by Puritan John Cotton in 1641, established capital punishment as the only response to intentional murder and listed scripture to support this judicial position:
“Murder, which is a wilful man-slaughter, not in a man’s just defence, nor casually committed, but out of hatred or cruelty, to be punished with death. Ex. 21:12, 13. Num. 35:16, 17, 18, to 33. Gen. 9:6.”5
Puritan Matthew Henry wrote in his commentary on Genesis 9:
“The magistrate must punish murderers. … Before the flood, as it should seem by the story of Cain, God took the punishment of murder into his own hands; but now he committed this judgment to men, to masters of families at first, and afterwards to the heads of countries, who ought to be faithful to the trust reposed in them. Note, Wilful murder ought always to be punished with death. It is a sin which the Lord would not pardon in a prince (2 Ki. 24:3, 4), and which therefore a prince should not pardon in a subject.”6
The Reformers expected capital punishment to always be the mode against convicted murderers. Asking for less is unbiblical and out of touch with church history. That is effectively what a duress defense would do. It would reduce the harshest punishment against a willful murderer to a sentencing other than the death penalty. Such a legal precedent will teach women that so long as there is pressure on them, however rehearsed, artificial, or synthetic it might be, they can murder their babies with impunity or lesser sentencing than others under similar coercion.
Even though proving duress is difficult and, we might confess, a nearly impossible task for a pregnant woman to successfully demonstrate, the fact remains that we open it up as a possibility for the jury to consider on her behalf. The higher principle here is God’s holiness and image, which is why Christians have always held a firm line on the death penalty.
6.1. Battling the Judicial Revolution
Rather than seeking to extend the duress defense for murder in states that don't recognize it, Christians should instead work to repeal it in places where duress is a recognized defense against murder and reestablish the death penalty in states that are not scripturally aligned with Genesis 9:6-8. This can be a separate initiative from abolition bills or abolition bills can defy the unjust application of a duress defense for murder. Nonetheless, this should be actively pursued by all Christians, not just those within the Abolition Movement.
G. Disincentivizing Self-Reporting?
“... without a duress defense, the mother would be strongly disincentivized from reporting at all.”
It’s worth pointing out that the above quote is the same rhetoric used by pro-life leaders against equal protection and justice under homicide law for prenatal children. Particularly, they object that classifying aborting women as murderers will reduce the likelihood of them turning on abortionists. Consider the following quotes:
“…if the woman were a criminal co-conspirator with the abortionist, in the common law tradition the abortionist could not be convicted on the basis of the woman’s uncorroborated testimony — and all too often there were no other witnesses and no other evidence. This problem was also solved by treating the woman as a victim rather than as a co-criminal.” – Matthew Franck, Redford University professor and chairman of political science.7
“Even if we reject the view that the woman who chooses an abortion can also be a victim, there’s a compelling reason to avoid holding her legally culpable: we want to prosecute abortionists. The purpose of forgoing prosecution of the mother is not to let them evade the moral consequences of their actions, but to help ensure the principal criminal—the abortionist—would be identified, prosecuted, and brought to justice.” – Joe Carter, The Gospel Coalition senior writer.8
“[Before Roe] Most states’ statutes did not allow for the prosecution of women seeking abortions, and in states that did have statutes prohibiting women from performing self-abortions or consenting to an abortion performed by another, no women were prosecuted. The reason for this is simple enough. The record of state abortion laws before Roe makes clear that the laws targeted for prosecuting the abortionists themselves—the “principals” of the act—rather than the pregnant women—the “accomplices.” In fact, most states did not even regard the woman as an accomplice. Some classified the woman in law as a victim of the abortionist. The reason for this was partly practical: if the woman is considered an accomplice to the crime of abortion, she cannot testify against the principal—the abortionist, in this case—in court, thus weakening the state’s ability to effectively enforce the law against abortionists.” – Tim Bradley, Charlotte Lozier Institute research associate.9
7.1. Hidden Crimes: Problem for the Law?
It's possible that if there is no duress defense for prenatal murder then women will not incriminate themselves by turning on the person who put them under duress in the first place. But this is not a problem for scripture. Justice demands accountability for murder regardless of duress or the honor system. We don’t have to lessen the charges for a woman to come forward against a solicitor anymore than we need to provide legal cover for a woman to come forward against an abortionist. A woman’s sin will eventually find her out (Num. 32:23) because God will expose every secret thing (Ecc. 12:14) in order that all may give an account before Him (Heb. 4:13). Our justice system has limits but God’s justice does not. This is not a problem, legally, either. The primary reason criminals hide their crimes or run from accountability is always to evade the consequences of their crimes; the very crimes for which their consciences bear witness against them before God.
If the goal is to mitigate the act of murder and protect women from compulsion situations, we could strengthen the penalties against a solicitor by not allowing a reduced sentencing for anyone who criminally pressures another person to commit murder. To be biblically aligned, this would mean the instigator is only eligible for capital punishment if found guilty and not eligible for lesser sentencing.
Conclusion
In conclusion, God’s Word is simple and clear: Murder under compulsion is still murder. As such, we cannot acquit the guilty mother or show judicial partiality toward her, regardless of a child’s biological dependency on her. It is better to obey God than to save the most lives possible. Saving the most lives possible opens the floodgates to a deluge of legal loopholes and exploits that will only lead to further injustice and pollution in the land. Ultimately, do we really want to provide a legal excuse for maternal aggression, an act that scripture always denotes as severe depravity and rebellion and a form of God’s judgment against a nation or individual?
“The hands of compassionate women have boiled their own children; they became their food during the destruction of the daughter of my people.” – Lam. 4:10
“The most tender and refined woman among you, who would not venture to set the sole of her foot on the ground because she is so delicate and tender, will begrudge to the husband she embraces, to her son and to her daughter, her afterbirth that comes out from between her feet and her children whom she bears, because lacking everything she will eat them secretly, in the siege and in the distress with which your enemy shall distress you in your towns.” – Deut. 28:56
Under duress, a woman’s heart would be revealed. Principles should be adopted before a crisis hits. When in crisis, the heart is tested and fidelity to any professed principle is revealed. Will a mother succumb to the moral temptation to end her child’s life to save her own, or will she fight to the death to protect her and the child and remain innocent of her baby’s blood? Our justice system should only reward the latter.
By Kayla Suderman with contributions from Amir Haqiqati
Blackston, William. “Commentaries on the laws of England.” Pg. 4.Commentaries on the laws of England. 1768: Vol 3 : Blackstone, William : Free Download, Borrow, and Streaming : Internet Archive
Pufendorf, Samuel. “The whole duty of man according to the law of nature.” Pg. 73-74. The whole duty of man according to the law of nature : Pufendorf, Samuel, Freiherr von, 1632-1694 : Free Download, Borrow, and Streaming : Internet Archive
Understanding Duress Provisions in Equal Protection Legislation — Foundation to Abolish Abortion
Calvin, John. “Commentary on Exodus.” https://www.ccel.org/study/Exod_21%3A22-21%3A23
“An Abstract of the Laws of New England, as They Are Now Established. By John Cotton | Reformed Theology and Apologetics.” 2024. Reformed.org. 2024. https://reformed.org/ethics/an-abstract-of-the-laws-of-new-england-as-they-are-now-established-by-john-cotton. An Abstract of the Laws of New England, as They Are Now Established. by John Cotton | Reformed Theology and Apologetics
Henry, Matthew. “Commentary on Genesis 9.” Blue Letter Bible. Commentary on Genesis 9 by Matthew Henry
NR Symposium, “One Untrue Thing.” National Review, August 1, 2007, www.nationalreview.com/2007/08/one-untrue-thing-nro-symposium/.
Carter, Joe, “Should Women Be Prosecuted for Self-Induced Abortions?” The Gospel Coalition, April 14, 2022. www.thegospelcoalition.org/article/women-prosecuted-abortions/.
Bradley, Tim. “Protecting Life, Not Punishing Women.” Charlotte Lozier Institute, October 6, 2016. Protecting Life, Not Punishing Women - Lozier Institute
