Suggestions for Achieving Consensus in a Post-Roe America
Bioethics in Law & Culture Winter 2022 vol. 5 issue 1
Mary M. Parker, M.A.
Director of Legislative Affairs
Ohio Right to Life
With the Supreme Court hearing the case of Dobbs v. Jackson Women’s Health Organization there is renewed hope for the realization of a post-Roe America where the scope of abortion laws would be determined by the will of the people, either through elected officials or referendums. Certainly, this outcome would be a victory for the pro-life movement, which for decades has pushed against current jurisprudence that recognizes abortion as a constitutional right. However, if the Supreme Court overturns Roe, the pro-life movement will find itself with a new challenge: voter backlash.
Although states have incrementally passed pro-life legislation, hitherto, these laws have mostly been enjoined by either federal or state courts and remain ineffective. These incremental legislative changes have not resulted in incremental changes in society at large. This sudden change, where pro-life laws are quickly enacted, may jettison the abortion issue from the periphery to center stage.
If abortion regulations can be determined by individual states, the pro-life movement will need to gain greater consensus among voters. I believe that this consensus can be achieved in part by a shift in rhetoric and strategy. The abortion debate should not only focus on outlawing abortion and defending the dignity of each unborn child, but it should also, to a greater extent, address the circumstances and culture into which that child will be born. In short, pro-lifers must focus not only on the abolishment of abortion but also building a culture of life. For the most part, I believe that pro-lifers would agree with this statement and are working towards this end.
It is likely that most pro-lifers have not considered the underlying philosophical principles that inform our actions and rhetoric. Therefore, this paper will address some of the underlying philosophical concepts of the abortion debate in the United States, and how pro-lifers should perhaps reconsider some of them. I will use the Dobbs v. Jackson Women’s Health Organization case as an example of the abortion debate in America today, and from that case, I will extrapolate the underlying philosophical principles, such as human dignity, individualism, and the common good. This certainly is not intended to be an exhaustive study, but rather a point of reflection for pro-lifers.
Dobbs v. Jackson Women’s Health Organization: A Snapshot of Contemporary Rhetoric
The case of Dobbs v. Jackson Women’s Health Organization was heard before the Supreme Court on December 1, 2021, thanks to a Mississippi law (HB 1510) that bans abortions after fifteen weeks of pregnancy. The case was taken up by the Supreme Court with the intention of answering the following question: should all pre-viability abortions be considered unconstitutional? In addressing this question, both the petitioners and respondents also addressed the larger issues, illustrating the political rhetoric often used by both sides.
Although the justices heard from thousands of people and organizations before the historic case, only three lawyers appeared before the Court during oral arguments. Not surprisingly, each had an impressive pedigree. The petitioners were represented by Mississippi Solicitor General Scott G. Stewart who was appointed by Mississippi Attorney General Lynn Fitch in 2021. Before serving in Mississippi, Stewart held the position of Deputy Assistant Attorney General in the Civil Division of the Department of Justice during the Trump Administration. There he defended the Mexico City policy. He also served in the United States Department of Justice’s Office of Legal Counsel and served as a clerk to Justice Clarence Thomas.
The respondents were represented by Julie Rikelman and Elizabeth Prelogar. Julie Rikelman serves as the Litigation Director for the Center of Reproductive Rights represented Jackson Women’s Health Organization, Mississippi’s last abortion clinic. Attorney General Elizabeth Prelogar argued for the federal government as an amicus curiae supporting the respondents. Weeks before the Dobbs v. Jackson Women’s Health Organization case, Prelogar argued that the federal government could mount a federal challenge to Texas’s Heartbeat Law (SB 8), which prohibits abortion after the detection of a fetal heartbeat. Prelogar is a graduate of Emory University and Harvard Law School, and she clerked for both Ruth Bader Ginsburg and Elena Kagan.
Stewart began his arguments by emphasizing the untenable nature of abortion law in the United States. According to Stewart, “Roe v. Wade and Planned Parenthood v. Casey haunt our country. They have no basis in the Constitution...” and “they have damaged the democratic process.” We see from the passage of pro-life laws throughout the country that Stewart is correct. States that have an interest in protecting unborn life cannot do so because the Supreme Court has become the arbiter of the legality of abortion. Stewart argued that the Court cannot solve this issue that it created, saying, “For fifty years [abortion laws] have kept this Court as the center of a political battle that it can never resolve.”
Those in favor of pro-life laws argue that the only workable solution would be to allow states to regulate abortion once again, as was the case before Roe v. Wade. At a state level, the various interests of the people could be represented, either through statewide elected officials or referendums. Regarding this issue, Stewart said, “The Constitution places its trust in the people. On hard issue after hard issue, the people make this country work.” He continued by adding, that abortion “demands the best from all of us, not a judgment by just a few of us.” Stewart also remarked that in cases of assisted suicide and other issues that pertain to “dignity, autonomy, freedom, and important matters of conscience” the Court has allowed the people to address these issues.
Stewart also emphasized the humanity of unborn children. The advances in science and medicine during the past fifty years have helped illustrate the humanity of these children. In response to a question from Justice Breyer, Stewart said, “It’s an advancement in knowledge and concern about such things as fetal pain...we know what the child is doing, and looks like, and is fully human.” Roe and Casey preclude states from addressing the issues of fetal pain and advances in medicine. Stewart also noted that the Court itself in the Gonzales v. Carhart case in 2007 “recognized that before viability, we are talking about an unborn life with a human organism.”
Both Stewart and several justices questioned the arbitrariness of the viability standard. Stewart said, “People can protect an unborn girl’s life when she just barely can survive outside the womb but not any earlier when she needs a little more help. That is the world under Roe and Casey.” In a line of questioning addressed to Rikelman, Justice Alito said, “Look at the interest on the other side. The fetus has an interest in having a life, and that doesn’t change does it, from the point of viability to the point of after viability.” Because an unborn child is a living human person, regardless of the gestational age or viability, abortion purposefully ends the life of an unborn child.
Because abortion is the killing of an unborn child, abortion is the only issue in which the Court has recognized the right to end the life of a human life. Stewart said, “Nowhere else does this Court recognize a right to end a human life.” This right has purposefully led to the termination of over sixty-five million lives since 1973.
The pro-choice arguments before the Court were more limited in scope compared to the pro-life arguments offered. They primarily focused on the argument that the Fourteenth Amendment of the Constitution guarantees women bodily autonomy, which provides for the right to an abortion. In her opening remarks Rikelman stated, “For a state to take control of a woman’s body and demand that she go through a pregnancy and childbirth...is a fundamental deprivation of her liberty.” Prelogar made similar comments in her opening remarks, saying, “For a half a century, this Court has correctly recognized that the Constitution protects a woman’s fundamental right to decide to end a pregnancy before viability. That guarantee that the state cannot force a woman to carry a pregnancy to term and give birth has engendered substantial individual and societal reliance.” Prelogar added that the Fourteenth Amendment “promotes interest in autonomy, bodily integrity, and equality.” As shown by these arguments, the state cannot regulate abortion pre-viability because it would deny her individual liberty. Should the Court overturn federal abortion jurisprudence, Prelogar said that the “Court would be telling the women of America that it was wrong, that actually the ability to control their bodies...is not a part of their protected liberty.” The Court would rescind a right that it had previously acknowledged and respected.
To deny a woman the right to an abortion would consequently deny her equal status in American culture. Rikelman argued that “in fact, the data has been very clear over the last 50 years that abortion has been critical to women’s equal participation in society. It’s been critical to their health, to their lives.” Rikelman furthered this line of argument by saying later, “Women have an equal right to liberty under the Constitution...and if they’re not able to make this decision, if states can take control of women’s bodies and force them to endure months of pregnancy and childbirth, then they will never have equal status under the Constitution.” Indeed, by allowing the states to control abortion regulations, women throughout the country would be placed into varying categories, with greater or lesser rights, depending on the abortion legislation. For the pro-choice movement, because pregnancy and childbearing are a unique burden to women, they need abortion to maintain their equal status with men. Additionally, the decision to have an abortion should only be made by the pregnant woman herself.
Since the state has upheld the constitutional right to an abortion, society has come to rely on it. Prelogar pointed out that Casey recognized the individual reliance of women and their partners to organize their lives and make important life decisions against the monumental decision whether to have a child. She added, “And people make decisions in reliance on having that kind of reproductive control, decisions on where to live, what relationship to enter into, what investments to make in their jobs and careers.” One in four America women have obtained an abortion, in an attempt to control the circumstances of their lives. According to these arguments, Americans need abortion to be successful in their personal and professional lives.
By appraising some of the arguments of the Dobbs v. Jackson Women’s Health Organization case, it is evident that there is very little common ground. The only common ground is perhaps that both sides recognize that this is a challenging and personal issue for many Americans. The pro-life petitioners argued that states have a valid interest in regulating all abortions, which result in the killing of an unborn child, and that the American people are better suited to handle this issue than the Supreme Court. The pro-choice respondents argued that the Court has recognized a woman’s right to an abortion, a right which society relies on, and to allow the state to regulation abortion access would be tantamount to creating distinct classes of women who would have different statuses under varying state laws. Justice Kavanaugh pointed out these fundamental differences saying, “the reason this issue is hard, is that you can’t accommodate both interests. You have to pick. That’s the fundamental problem. And one interest has to prevail over the other at any given point in time.” There can be no balancing act when life and death are on the line.
2. The Underlying Philosophical Assumptions of Contemporary Abortion Rhetoric
These conflicting conceptions of human dignity and the role of the individual form a part of the contemporary abortion debate. For the pro-abortion advocates human dignity is determined by liberty. The law respects the dignity of the human person, insofar as the state protects the liberty or autonomy of that person. Pro-life advocates argue that the state should recognize the dignity of the unborn person by recognizing the right to life. However, this right to life is not necessarily based on liberty, but rather it recognizes the dependency and vulnerability of the human condition; an unborn child needs her mother’s support to be born and continue living. Ultimately, these rhetorical arguments illustrate the value judgments that American culture makes about human life, and how it defines which persons are worthy of life.
It is important to note how political history has influenced the Western conception of the human person and human dignity. As Chad Pecknold points out in The Postliberal Order, in classical Western philosophy, as demonstrated by Cicero, Livy, and Tacitus, dignity (dignitas) “conferred authority upon someone due to their rank, social standing, and especially their family.” For the Romans, the concept of dignity was closer to “keeping one’s good name” rather than a standard for equality. However, this concept of equality drastically changed following the atrocities of World War II.
Alasdair MacIntyre recently commented on this recent shift in our understanding of human dignity when he presented a talk entitled “Human Dignity: A Puzzling and Possibly Dangerous Idea?” at the fall conference of the de Nicola Center for Ethics and Culture at the University of Notre Dame. He reflected on how, following World War II, human dignity became “something that all human beings have, and their having it entails that we owe every human being respect.” This definition, although vague, became prevalent after World War II, and it can be seen in post-war European constitutions and the United Nations’ Universal Declaration of Human Rights. MacIntyre suggests that this vagueness “was deliberate, because it was designed to secure rhetorical agreement among people who did not agree on substantive matters.” This conception of human dignity created a “set of minimal standards outlining how to treat one another after the atrocities of World War II.” It was from these minimal standards that society could rebuild after the war. While these minimal standards created the veneer of consensus, Dr. Chad Pecknold explains that they have been “used to secure subjective rights” and “we’ve lost both justice and dignity in the migration of meaning where dignity shifts from something socially established by familial and nobiliary bonds to something inviolably equal in all.”
Like post-war Europe, American liberalism tends to rely on minimalistic standards which are determined by individualism. D.C. Schindler explains that liberalism has triumphed because it has “deposed truth as the standard by which reality is measured and, in a certain sense, replaced it with nothing at all, insofar as having a standard of any genuinely transcendent sort inevitably brings one back inside a horizon set by truth.” Because of this lack of transcendent standard, the individual and individual freedom becomes a new standard. According to Schindler, liberalism is “committed to a reductive rationalism in politics that coincides with its ontological individualism.”
America’s founding documents reflect this way of thinking. The Declaration of Independence and the American Constitution outline how each person is entitled to private rights and freedoms, upon which the government cannot trespass. As stated in the Declaration of Independence all men are created equal and endowed by God with certain unalienable rights including liberty and the pursuit of happiness. The Declaration states that government is instituted to secure these rights and gains its power from the consent of the governed. It is the role of the government to provide freedom so that individuals may flourish as they see fit. These founding documents have allowed for unity among the many diverse ethnic and religious groups in America.
This emphasis on individual freedoms in America has led to a minimalistic idea of the political common good, which should be promoted or protected by the government. In his critique of Integralism, Adrian Vermeule published in The American Mind, C. Bradley Thompson concludes that his vision of the common good is one where the State “leaves law-abiding citizens alone...to pursue their vision of a good life.” He disagrees that there is one “absolute, universal, eternal, [and] knowable” common good to guide public policy. Rather, as illustrated by American pluralism, there are “innumerable and competing” definitions of the common good or a good life, which then influences different group’s public interest in promoting certain goods.
According to Thompson, the State and politicians cannot better the lives of American citizens. To illustrate, he poses the question, “does anyone seriously believe that Harvard professors, the Vatican’s College of Cardinals, or Deep State bureaucrats actually know what is best for ordinary Americans better than ordinary Americans?” He argues that in a liberal democracy, where rival factions compete for power, each faction will only try to impose its vision of the common good on others. The Left has historically “believed that government must determine which material goods should be common to all people, how such goods were to be produced, by whom, and how they shall be redistributed” while the Right “believed that government must determine which spiritual goods should be common to all people, and how and by whom such goods will be produced and enforced.”
Pro-abortion advocates determine that an unborn child is a person and has rights based on individualistic and utilitarian principles. If an unborn child is wanted and the socio-economic conditions are favorable to having a child, then that child is worthy of life and celebrated. If an unborn child has the potential for achievement, i.e. that child is not born with Down syndrome or another disability, then that child is worthy of life. According to pro-abortion advocates, the person who determines the value and personhood of an unborn child is an individual, the pregnant woman, since she alone is affected in a particular way by pregnancy, childbirth, and childrearing.
By employing this utilitarian rationale, it creates two distinct classes of people in the United States: those who deserve moral concern and those who do not deserve moral concern. According to Dr. John O’Callaghan, in his talk “Are There Failed Persons?”, those who merit moral concern are those rational and autonomous individuals who are moral agents. The individual can set goals and achieve them, to determine what pleases them or not. If we follow Prelogar and Rikelman’s arguments in favor of abortion, it follows that abortion allows Americans, who are rational and independent moral agents to actualize their capabilities, because it allows them to determine the circumstances of their life and choose whether they want a child.
Those in favor of abortion also rely on the tradition of supporting individual freedoms in America and a minimalist understanding of the common good. It should be the right of each woman to determine whether to have an abortion, and the state should allow her the freedom to do so. To act otherwise would be a denial of her individual freedom. This is seen very clearly in Rikelman and Prelogar’s arguments.
3. Americans’ Perception of Abortion
Polling shows that a majority of Americans consider themselves “pro-choice.” The January 2021 Knights of Columbus and Marist Poll National Survey found that 53% of Americans considered themselves “pro-choice” while 43% consider themselves “pro-life”. Only 4% were unsure. 27% of pro-choicers believed that women should be able to obtain an abortion during any time of pregnancy, while even only 12% of pro-lifers were in favor of abortion bans. We find that most Americans want stipulations on abortions that consider exceptions and the gestational age of the child.
Even so, polling on the abortion issue can lend towards polarities and it oftentimes overlooks the nuanced opinions that many Americans have about abortion. I found Dr. Tricia C. Bruce’s study How Americans Understand Abortion a helpful read in trying to understand the human response to such a controversial topic. Bruce and her team conducted 217 in-depths interviews that demographically represented a cross-section of Americans. The interviews lasted seventy-five minutes, and they were designed to “elicit thoughts, feelings, and experiences connected to abortion attitudes.” When deciding whether to agree to the study, the interviewees did not know that they would be discussing abortion.
In her findings Bruce found that abortion impacts the lives of many Americans but not in a positive way. Not surprisingly, one quarter of female interviewees recounted a personal abortion story while three quarters knew someone who had had an abortion. Bruce writes, “Abortion is not a hypothetical exercise in ideology or doctrinal adherence, but a lived and often fraught experience.”
The controversial nature of abortion impacts how people discuss it. Despite the political shouting matches in the public square, there is silence surrounding abortion. Interviews revealed that “most Americans have not given careful thought to abortion beyond how labels, politics, and media frame the public conversations.” Many do not know how they feel about abortion and “find themselves bereft of scientific, legal, and moral lexicons to reason through difficult topics...” This results in people often giving an answer to a survey that does not reflect the depths of their opinion or their uncertainty. According to Bruce, most Americans are conflicted in their attitudes toward abortion and have multidimensional views that are not always portrayed by surveys.
Americans do not view abortion as a good to be pursued. Bruce writes, “None of the Americans we interviewed talked about abortion as a desirable good. Views range in terms of abortion’s preferred availability, justification or need, but Americans do not uphold abortion as a happy or even something they want more of.” Abortion is a hard choice that is often a means to an end. Americans often consider the circumstances of the pregnancy, and they would prefer to eliminate or reduce the circumstances that lead a woman to choose abortion.
Ultimately, Americans want what they consider a good life for both children and parents. According to interviewees a “good life” includes “health, support, financial stability, affection, rights, and pursuit of chosen livelihoods.” Many who are permissive of abortion are so because of the perception abortion ensures a “good life”, rather than concern for the ethical concepts of personhood, rights, and responsibilities. Americans want a culture where individuals can thrive, and they question the value of life based on the suffering that might be brought about by unhappy circumstances.
I think the key term from Bruce’s study is the word conversation. If we wish to change hearts and minds on the abortion issue, we need to start focusing more on conversations rather than debates. As Bruce found from her study, Americans can talk about abortion, and it appears that they are willing to learn more about the issue under the right circumstances. This conversation must be compassionate, personal, and one that seeks to find the common ground between mothers, fathers, and unborn children.
4. New Rhetorical Arguments for the Pro-Life Movement
If pro-lifers want the American people to make the legal decisions about abortion, either through elected state officials or referendums, the pro-life movement must prepare them. From Bruce’s study, we find that the American people are willing to talk about the issue, but they shy away from the polarizing political shouting matches that have characterized the abortion debate since 1973. As a cultural and political movement, we need to update our arguments and some of our philosophical and political assumptions. Of course, we must do so without compromising our belief that each person has inherent right to life. We must, in one way or another, find enough common ground to start building a culture of life.
Rhetorically, the pro-life movement typically relies on arguments regarding human dignity and rights. Each human person, born or unborn, has inherent worth and dignity simply by being human. Because abortion is the killing of an unborn child, we must protect that unborn child by banning abortion. All of these statements are certainly true.
Yet, these statements also fail to address the subjective and utilitarian nature of the pro-choice opposition. We have seen that the term human dignity post World War II, in a certain sense, has a subjective meaning that fails to create real, political, and societal cohesion. We sense this in practice, simply by reading the oral arguments of the Dobbs case. This debate is also negative, and often times leaves people grappling with the question of what should be done instead, if abortion is no longer an option.
Instead of primarily focusing on negative precepts and the issue of human dignity, I think we should start incorporating positive precepts into our arguments and considering the culture as a whole. Some, particularly conservatives who argue for smaller government, may balk at positive precepts. Positive precepts recognize duties and obligations and accompany human rights.
While American liberalism has championed autonomy and individualism, pro-lifers must recognize the good of interdependency of human society. Dr. John O’Callaghan addresses how the pro-abortion or utilitarian worldview fails to recognize this interdependency. As O’Callaghan points out, “autonomy is conditioned by life with others and determined by dependence on one another.” For example, we see this in the various exchanges of everyday life. A young child depends on his parents for care. I buy a coffee from the local café. A doctor heals a sick patient. This dependency is caused in part because humans develop gradually over time. Those who are very young and very old typically are more dependent on others than adults. Those who are sick or disabled require more attention and care.
Human dependency is not a bad thing. In fact, O’Callaghan argues that it is through befriending and caring for those who are vulnerable that the human person actualizes his or her capabilities. It is through friendship with all those who share in the human condition that one is successful and finds meaning. To kill the weak and the dependent, including unborn children, is an act that destroys one’s friends and destroys oneself, since it is through friends that one finds happiness and self-actualization. We must convince our culture that although accepting another’s vulnerability and cultivating a friendship can be arduous, this good is greater and more fulfilling that the good of selfish egoism, which is often fleeting.
This argument can help counter the pro-abortion argument based on individualistic and utilitarian self-determination. Clearly, the unborn child is dependent on her mother, but that mother in crisis pregnancy is also dependent on others for help and support. If abortion is to be abolished, communities need to take on a greater responsibility for a woman in a crisis pregnancy, even if it is only for the sake of her unborn child. Women should not feel as if they are pressured into making this decision alone, but that there are others in the community who are willing to help her. We cannot focus only on the baby, but we need to recognize that in the crucial moment of whether to have an abortion, a mother is often thinking of herself or feeling pressured to have an abortion.
We need to prepare for the reality that there will be thousands of women and families in need should abortion be outlawed by certain states. Collaboration will be necessary between pregnancy centers, hospitals, churches and church groups, and other pro-life organizations. Although still a fairly new organization, Her PLAN addresses seven categories of care that can help empower women to choose life, including: mentorship, health and well-being, financial assistance work or education, material and legal support, mental health support, prenatal diagnosis support, and care for children.
If we recognize this innate human dependency, we should also recognize that there are certain goods that can only be achieved through cooperation, and that some of these goods are common goods. I certainly do not agree that the government should arbitrarily decide what are common goods. I agree that the term has unfortunately been used for ill, especially by totalitarian regimes. At the same time, the fragmentation of American culture, caused by several factors, including identity politics, has caused significant unrest and even violence in certain cases. It often feels like our society is unraveling. To a certain extent we do need consensus as to what constitutes a good life and how we are to achieve this together as a society without trampling upon individual rights.
I believe that a more holistic understanding of the common good would be helpful for healing our culture. Dr. Steven Long explains that a common good is “a good of and for the individual, but it is not an individual good.” Common goods are by their nature “communicable to many without diminution” and “more intelligibly irradiant, more universal, precisely as an end.” For example, peace is a common good that can be enjoyed by all members of the community, and by one member partaking of the peace, it does not exclude another. Common goods are not simply aggregates of material goods. Rather, common goods are ends to which we should strive, such as peace and justice.
For Aristotle and later Aquinas, the common good entails the proper ordering of society. For modern Americans, the semantics of the common good can seem to be tainted by collectivism or totalitarianism. But the goal of law and pursuing common goods helps promote virtuous living among cities and the proper ordering of society. From this ordering, citizens can enjoy the tranquility of order. This ordered life includes not only survival and material prosperity but also the community’s happiness and virtue. As Dr. Long states, “the political common good is the good of an ordered multitude in relation to the happiness, which is found in virtuous living.”
From a legislative perspective, this would include funding for pregnancy centers and other institutions that help those vulnerable to abortion. I think that Texas has set a good example. As Texas passed its Heartbeat Law, it also allocated one hundred million dollars to its Alternatives to Abortion program. Another example is Ohio, which allocated six million dollars to the Ohio Parenting and Pregnancy Programs. With these programs, the government acts in such a way as to promote life-affirming alternatives to abortion and create positive cultural changes.
Additionally, funding pregnancy centers, taxpayer dollars are saved. In 2017, on a national level, pregnancy centers saved their communities at least $161,008,203 by subsidizing healthcare and other services at no cost to their clients. In Michigan, the agency manager of their pregnancy centers reported a total of forty-four million dollars in tax savings in 2017, which is a return-on-investment of over $13 for every $1 spent.
From a cultural perspective, I believe that the pro-life movement will have to organize itself to support pregnancy centers to a greater extent. At Ohio Right to Life, I have been advocating that our chapters begin working closely with pregnancy centers to help address their needs. According to National Right to Life, there are more than 3,000 local pro-life chapters throughout the country. If organized, properly, these chapters will certainly be a pro-life force to be reckoned with.
In a post-Roe America, the pro-life movement will need to gain consensus among average Americans who will be determining abortion laws at the state level. To do so at a grassroots level, pro-lifers will need to address their local communities and provide more resources for pregnant mothers and parents in their local communities. At a legislative level, state governments should consider appropriating funds to pregnancy centers and other pro-life community organizations to help those vulnerable to abortion.
On a deeper level, the pro-life movement should assess the underlying philosophical worldviews that deeply affect American culture. If we are to build a culture of life, we must recognize the innate dependency of the human condition that binds us together in various relationships. It is through pursuing a good life by cultivating virtue that we not only better our friendship but pursue common goods, such as justice and peace, which belong to all for the sake of all.
 Dobbs v. Jackson Women’s Health Organization, 19-1392, (Supreme Court 2021)
 Ibid., 5
 Ibid., 17
 Ibid., 30
 Ibid., 5
 Ibid., 65
 Ibid., 48
 Ibid., 84
 Ibid., 89
 Ibid., 52
 Ibid., 78
 Ibid., 96
 Ibid., 106
 Chad Pecknold, “The Loss of the Ennobling Principle,” The Postliberal Order (The Postliberal Order, November 16, 2021), https://postliberalorder.substack.com/p/the-ennobling-principle.
 Alasdair MacIntyre, “Human Dignity in a Secular World,” Human Dignity in a Secular World.
 “Loss of the Ennobling Principle”
 D.C. Schindler, “Challenging the Terms of Liberalism: On the Politics of Virtue,” Nova Et Vetera 16, no. 4 (2018): pp. 1353-1369, 1353.
 C. Bradley Thompson et al., “Tyranny and the Politics of the Common-Good,” The American Mind (The Claremont Institute, October 11, 2020), https://americanmind.org/features/waiting-for-charlemagne/tyranny-and-the-politics-of-the-common-good/.
 John O’Callaghan, “Are There Failed Persons? Are You One of Them?,” (The Thomistic Institute, September 4, 2020).
 “American's Opinions on Abortion” (The Knights of Columbus and Marist Poll, January 2021), http://kofc.org/en/resources/news-room/polls/americans-opinions-abortion.pdf.
 Tricia C. Bruce, How Americans Understand Abortion, (Notre Dame, IN, 2020).
 Ibid., 52
 Ibid., 54.
 O’Callaghan, “Are There Failed Persons? Are You One?”
 “Alternatives to Abortion,” Texas Health and Human Services (State of Texas), accessed January 13, 2022, https://www.hhs.texas.gov/services/health/women-children/alternatives-abortion.
 Steven A. Long, “Understanding the Common Good,” Nova Et Vetera 16, no. 4 (2018): pp. 1135-1152, https://doi.org/10.1353/nov.2018.0042, 1140.
 ““Alternatives to Abortion,” Texas Health and Human Services (State of Texas), accessed January 13, 2022, https://www.hhs.texas.gov/services/health/women-children/alternatives-abortion.
 Moira Gaul and Mai W. Bean, “A Half Century of Hope, a Legacy of Life and Love: Pregnancy Center Service Report, Third Edition,” Charlotte Lozier Institute, September 28, 2018, https://lozierinstitute.org/a-half-century-of-hope-a-legacy-of-life-and-love/.