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Abortion and the Law: Three Clarifications
from Slaughter of the Innocents: Abortion, Birth Control and Divorce in Light of Science, Law, and Theology
by John Warwick Montgomery

''The unexamined life," declared Socrates, "is not worth living." Though this aphorism might seem to favor a proabortion view (since the unborn are in a poor position to examine their own raison d'être), we see it as a neutral heuristic principle: the more closely one examines the particulars of any legal issue, the more likely will light appear at the end of the tunnel (Or womb). Our modest hope is to remove three misconceptions bearing on the legal aspects of the abortion question.

The method to be employed is a dangerous one: the jurisprudential examination of fundamentals. It was just such an approach that resulted in the firing of young attorney Littlefield from the prestigious firm of Bass and Marshall. Instead of a traditional brief citing cases, he had had the temerity to quote Cicero! "There were no cases cited from the Second Circuit at all. Sure, all the great jurisprudential scholars were there. Kant was there. Wittgenstein seemed to crop up...." The immortal last words spoken to Littlefield by the partner to whom he submitted his work were: "Don't call this-a brief."1 But whatever the present memorandum is called, it should at least aid those concerned with the legal aspects of abortion to think more clearly on the subject.

Clarification One: Roe v. Wade Does Not Leave the Personhood of the Fetus as an Open Question

Discussions of the current status of the abortion issue in American law frequently go on the assumption that change in abortion law in general and the revolution stemming from Roe v. Wade in particular do not require any ultimate decision as to whether the unborn are in fact "persons." This view is mightily reinforced by Mr. Justice Blackmun. speaking for the Court:

We need not resolve the difficult question of when life begins. When those trained in the respective disciplines of medicine, philosophy, and theology are unable to arrive at any consensus, the judiciary, at this point in the development of man's knowledge. is not in a position to speculate as to the answer.2

But the pragmatic results of the decision in Roe v. Wade have left little doubt in the minds of the general public, whether sophisticated or unsophisticated, that the personhood of the unborn has undergone radical redefinition. One of California's most venerable and controversial trial lawyers, Vincent Hallinan, thus referred to Roe v. Wade in arguing another case shortly after that decision came down in 1973:

Do you know who is the biggest dissenter, the most important dissent-er, in the world at the moment? It is the United States Supreme Court, which, just a short while ago, came down and, ignoring Congress, legislators, biblical invocations, and religious groups, outlawed anti-abortion laws. "A woman," it said, "is the master of her own body and if at least for the first three months of pregnancy she doesn't want to have a child, that's up to her and her doctor, and no state and no nation has the right to restrict her in it." That, my friends, is a dissent from a policy that has existed for over four thousand years.3

A former law clerk of Associate Justice Powell quotes a typical letter Powell received after he had joined the seven-man majority in Roe v. Wade:

Dear Justice Powell,

My name is __________ and I am 15 years old-a sophomore in high school...

I think it is wrong for a woman to have an abortion. Some people think it's not murder for someone to have an abortion, but I think it is. And when they make murdering helpless unborn children legal, how long will it be before it is legal to kill sick old people, the mentally retarded, etc.?

The Supreme Court, it seems to me, should be protecting the rights and lives of all people, not legalize the murder of the innocent people.

Please try to do whatever you can to help. Thank you for reading my letter.

Sincerely, 4

Are these gut reactions wide of the mark? Did the Court manage an act of subtle alchemy in transmuting the fetus's right to life into the mother's right of privacy, while still leaving the personhood of the fetus an open question? We think not.

Blackmun's assertion that "we need not resolve the difficult question of when life begins" is belied by his references to the fetus as having "potential life."5 Justice Stewart, in his concurring opinion, uses the descriptive phrase "potential future human life."6 Clearly, human life is not synonymous with potential human life; an opposition is being created between actuality and potentiality-to the detriment of the fetus's personhood. The unborn, at least during the first trimester of pregnancy, is accorded no more than potential (not actual) personhood, and his rights are being correspondingly attenuated.

That this construction of Roe v. Wade is not overdrawn becomes especially plain when we note Blackmun's admission that

The appellee and certain amici argue that the fetus is a "person" within the language and meaning of the Fourteenth Amendment. In support of this, they outline at length and in detail the well-known facts of fetal development. If this suggestion of personhood is established, the appellant's case, of course, collapses, for the fetus's right to Iife is then guaranteed specifically by the Amendment. The appellant concedes as much on reargument.7

Thus the Court, by necessary implication, rejects the appellee's argument that the fetus is a person within the meaning of the Fourteenth Amendment. In doing so it does, for good or for ill, "resolve the difficult question of when life begins" (or, at least. as to when life does not begin)-the opinions of physicians, philosophers, and theologians notwithstanding.

How could the Court arrive at its judgment, contrary as it is to "the well-known facts of fetal development"? How could it disregard the overwhelming evidence of contemporary genetics as to the personhood of the fetus?

This first cell [formed by sperm-and-egg union] is already the embryo of an autonomous living being with individual hereditary patrimony. such that if we knew the nature of the spermatozoid and the chromosomes involved, we could already at that point predict the characteristics of the child, the future color of his hair, and the illnesses to which he would be subject. In his mother's womb, where he will grow, he will not accept everything she brings to him, but only that which is necessary to his existence: thereby he will realize his hereditary patrimony. In that first cell the profound dynamism and the precise direction of life appears. . . . In spite of its fragility and its immense needs, an auton-omous and genuinely living being has come into existence. . . . It is rather surprising to see certain physicians speak here of "potential life" as if the fertilized egg began its real life when it nests in the uterus. Modern biology does not deny the importance of nidation, but it sees it only as a condition-indispensable, to be sure-for the development of the embryo and the continuation of a life already in existence.8

Such hard data are ignored by the Court because the Court convinced itself that it was not in fact deciding the question of the fetus's personhood, and did not need to do so to arrive at its abortion decision. "The unexamined life is not worth living." By not examining what it was really doing, the Court uncritically and gratuitously deprived the unborn of personhood.

But would it not be fairer to the Court to say that when Blackmun states that "we need not resolve the difficult question of when life begins" he is merely declaring that the Court's task is not to determine personhood in tact, but legal personhood'? Is not the Court simply sticking to its legal task and refusing to enter into the medical or scientific realm?

Perhaps this was the Court's intention. Even if so. however, this will not rehabilitate Roe v. Wade; quite the contrary. For one must not create a legal definition of personhood which flies in the face of medical evidence as to what a person in fact is. In National Socialist law, the Jew-regardless of genetic evidence of his humanity-was deprived of his legal personhood and destroyed like worthless offal.9 Prior to the American Civil War and the antislavery Amendments, such decisions as Dred Scott relegated slaves to the status of legal nonpersons in spite of clear biological evidence of their humanity.10 Wherever legal personhood has been defined without reference to objective genetic criteria, the door has been opened to the most frightful consequences.

As in the tragic examples just mentioned, the majority in Roe v. Wade were influenced far more by social and policy considerations than by biological fact. "This holding," they say. "is consistent with the relative weights of the respective interests involved. . . and with the demands of the profound problems of the present day."11 What problems'? In particular. the impassioned demand of many women to be (in the previously quoted words of Hallinan) absolute "masters of their own bodies."12 Only such essentially social considerations can explain the bizarre reliance of the Court on Brandeis' 1890 "right to privacy" doctrine in a situation which bears virtually no relation to the original meaning of that legal principle.13 (Would the Court now argue that whenever our privacy is potentially disturbed-e.g.. by prying neighbors or obnoxious newsmen-we may kill the source of the disturbance and the result will be justifiable homicide'?)

Into such a slough of despond did the Court stumble when it refused to face squarely the question as to when human life begins. It did not leave that essential question open; it closed it, to the untold detriment of the unborn. Perhaps, as in the Dred Scott case, nothing less than a constitutional Amendment will be required to rectify the muddy judicial thinking of the Court.

Clarification Two: The Recognition of the Unborn in Property and Inheritance Law Is of High Significance for the Abortion Issue

It is generally conceded, even by those favoring the current relaxed standard of abortion, that in the area of property law Anglo-American jurisprudence has maintained remarkable concern for fetal rights.

In contrast to abortion and homicide, property law has long been one where the fetus at its earliest stages has been given recognition. Two cases decided in the late eighteenth century are representative of English common law. Doe v. Clarke held that an unborn child is one of the "children living" at the time of a testator's demise, and Thellusson s'. Woodford enumerated fetal rights as including recovery, execution, devise and injunction. American courts were not hesitant to pick up the English common law, as evidenced by Hall v. Hancock in 1834 when it was held that a grandson born almost nine months after the testator's death was a beneficiary under a bequest to such grandchildren "as may be living at my death."

In America, Crisfotd v. Starr established the rule that an infant en ventre sa mere is deemed in esse for the purpose of taking an estate in remainder the same as if born.

The Rule Against Perpetuities is perhaps the best instance of the en ventre sa mere doctrine coming into play. It is well established that a child en ventre sa mere is a life in being at the death of the testator. This effectuates an extension of the period recovered by the Rule to 21 years and period of gestation.

In the area of trusts, the en ventre sa mere doctrine is just as firmly noted: upon the father's death, a child may be an income recipient of the father's trust before it is born.14

"Granted," is the usual response, "but all this means little or nothing, since where the right to life per se is at issue (homicide, etc.) protection has traditionally commenced only with 'quickening.' After all, we are dealing with a question of personhood; so property issues will perforce have little bearing."

This depreciation of the significance of property law for abortion discussion overlooks the place of property law in common law jurisprudence. In point of fact-as apologists for the socialist philosophy of law15 and as American radical lawyers16 have not ceased to declare (with disgust) - traditional Anglo-American law elevates the concept of property to a sacral level.

Holdsworth speaks of "the most unique branch of the common law - the law of Real Property."17 One of the ways in which that uniqueness manifested itself was in the high value placed upon property and the corresponding reticence of the courts or legislatures to tamper with existing property law. Writes Simpson in the concluding chapter of his standard Introduction to the History of the Land Law:

Those who did understand the system encouraged the view that it was dangerous to meddle with so elaborate a structure, upon which the sacred property rights of the people were based.

... The old concepts of the law are not roughly handled; the definitions of Littleton and Coke still find their place in a modern textbook; lawyers can still gravely dispute the modern effects of Quia Emptores. For all the legislative interference which it has suffered, the law of property continues to display an extraordinary measure of historical continuity.18

Why do property rights carry a sacral quality in the common law? Let us hear from the two most influential writers of general legal textbooks in the history of the common law: Blackstone and Kent.

Blackstone after discussing "The Rights of Persons" in Book I of his Commentaries, proceeds in Book II to treat "The Rights of Things" Book II Chapter 1 deals with "Property in General," and there we read:

There is nothing which so generally strikes the imagination, and engages the affections of mankind, as the right of property; or that sole and despotic dominion which one man claims and exercises over the external things of the world, in total exclusion of the right of any other individual, in the universe...

In the beginning of the world, we were informed by holy writ, the all-bountiful Creator gave to man "dominion over all the earth; and over the fish of the sea, and over the fowl of the air, and over every living thing that moveth upon the earth." This is the only true and solid foundation of man's dominion over external things, whatever airy metaphysical notions may have been started by fanciful writers upon this subject...

...In the case of habitations in particular, it was natural to observe that even the brute creation, to whom everything else was in common, maintained a kind of permanent property in their dwellings, especially for the protection of their young; that the birds of the air had nests, and the beasts of the field had caverns, the invasion of which they esteemed a very flagrant injustice, and would sacrifice their lives to preserve them. Hence a property was soon established in every man's house and home-stall. . . . 19

It will be noted that Blackstone unequivocally establishes property rights on a revelatory foundation, citing Genesis 1:28 and alluding to Jesus' words in Matthew 8:20 (parallel passage, Luke 9:58) as the source of his argument. For Blackstone, property law had divine sanction. Applying modern philosopher of religion Rudolf Otto's terminology, property in Blackstone's view was embraced in "the idea of the holy": it was sacral, an aspect of the numen tremendens et fascinosum.

Chancellor Kent, whose influence on American law in many ways corresponds to Blackstone's on English jurisprudence,20 likewise sets forth a numinous conception of property rights.

The sense of property is inherent in the human breast, and the gradual enlargement and cultivation of that sense, from its feeble force in the savage state, to its full vigor and maturity among polished nations, forms a very instructive portion of the history of civil society. Man was fitted and intended by the Author of his being for society and government, and for the acquisition and enjoyment of property. It is, to speak correctly, the law of his nature; and by obedience to this law, he brings all his faculties into exercise, and is enabled to display the various and exalted powers of the human mind.

...The right of property, founded on occupancy, is suggested to the human mind by feeling and reason prior to the influence of positive institutions.21

Particularly illuminating is Kent's citation of authorities for his position. He quotes Selden's definition of natural law and refers to Aristotle, Plato, Cicero, and to Hooker's Ecclesiastical Polity in the same connection. On the principle of occupancy as establishing property rights, he quotes the fundamental aphorism from Justinian's Digest, ''Quod enim nullius est id ratione naturali occupanti conceditur";22 the significance of this reference lies in the fact that Roman law distinguished between "civil" and "natural" acquisition of property, and classed acquisition by occupancy as ''natural'' (i.e., ''recognized by the jus gentium"23). Since the jus gentium is "that law which natural reason has established among all men, is equally observed among all nations, and is called the 'law of nations,' as being the law which all nations use,"24 Kent is saying that the root concepts of property ownership are part of the natural law deriving from no less a source than "the Author of [man's] being." Thus the Chancellor, though during most of his life ''inclined to Unitar-ianism" (as he put it)25 and so more comfortable with arguments from natural law than from the Bible-Blackstone's "holy writ" - held no less than Blackstone to a sacral view of property and of its concomitant legal relations.

Whatever may be the case in other legal systems, therefore, one cannot dichotomize person and property, to the detriment of the latter, in the context of the common law. Property, no less than personhood, is regarded as sacred-for both are part of the "natural law" and originate from the divine will.

Indeed, there is a sense in which property rights are superior to personal rights! Blackstone has already expressed his awe at "the right of property . . . that sole and despotic dominion which one man claims and exercises over the external things of the world, in total exclusion of the right of any other individual in the universe." Here he alludes to the distinction between rights in rein as contrasted with rights in personam: whereas personal rights (rights in contract, etc.) are available only against some particular or determinate person or persons, rights in rem are available against the whole world. Digby observes that "the law dealing with rights in rem may be called-using the term 'property' in a large sense-the law of property, or the law dealing with property rights.''

The rights and their corresponding duties which form the matter of English private law are first to be divided into two great classes, differing from each other in respect of the persons on whom the duties, which correlate to the rights, are incumbent. A person may have a right the essence of which consists in the fact that all other persons whatsoever are under a duty corresponding to the right; or he may have a right the essence of which consists in the fact that the corresponding duty is incumbent on some one or more determinate person or persons. An example of the first class of rights is the right of property which a person has in or over a piece of land or a herd of cattle. All other persons whatsoever are bound to abstain from acts injurious to his power of dealing as he pleases with his own, In other words, he may enjoy, use, and, if he pleases, if the thing is perishable, use up, the thing which is the subject of the right, subject only to certain general limitations, and also to certain special limitations prevailing in particular cases, where his rights are limited by conflicting rights possessed by other persons over the same subject. 'Rights of this class have received the name of rights in rem, an expression which means, not rights over things, but rights available against all the world, i.e., where a duty is incumbent on all persons whatsoever to abstain from acts injurious to the right.26

He continues, "If the word 'property' were not so ambiguous, one might venture to suggest that the 'law of property,' or 'of property rights,' should be substituted for the obscure expression 'rights in rem.'

In other words, common-law jurisprudence imparts an absolute quality to property rights ("against all the world") which it hesitates to find in the realm of personal rights as such. We may of course disagree with such a jurisprudential philosophy, but we can hardly deny that this is what the common law is saying.

Nor can we deny the implications of this high view of property for the issue at hand; namely, the extent to which the common law regards the fetus as a person. In that realm of the common law- property rights-where the protections afforded are the most unqualified and absolute (in rem), the fetus has most consistently been given recognition from the moment of conception. Putting it otherwise, when the common law has had its most unqualified rights at stake-inheritance, etc. - it has been the least willing to place the beginning of human life later than conception itself.

In light of this fundamental perspective of common-law jurisprudence, can we not agree with Byrn that the "quickening" issue is little more than a red herring?

Quickening was never intended as a substantive standard for the beginning of human life. It evolved purely as an evidentiary device. As a Massachusetts court observed in 1834: "The distinction between a woman being pregnant, and being quick with child, is applicable mainly. if not exclusively, to criminal cases" (Hall v. Hancock).27

In criminal cases, where the standard of proof has been very high (to a moral certainty, beyond reasonable doubt) it is understandable that evidentiary devices have been applied which give defendants the maximal benefit of the doubt. Quickening served as just such a device in an age of elementary medical knowledge. Today, however, we have far more sophisticated techniques for determining the existence of life in the womb, and it is hopelessly anachronistic to stress the medieval quickening rule. Even more important, as we have been at pains to show, the history and spirit of the common law should lead us back from this byway to the main thoroughfare: that fundamental principle of in em property law which declares that the rights of human beings are to be protected from the very moment of conception.

Clarification Three: The International and Comparative Law of Human Rights Favors the Unborn

One often gets the impression by listening to advocates of the current relaxed view of abortion that Roe v. Wade finally brought the United States out of traditionalistic obscurantism into the modern world. We have already seen, however, that the Court arrived at its decision by totally ignoring current genetic knowledge as to the commencement of human life. Now let us face the equally unpleasant fact that our American case law now flies in the face not only of modern science, but also of the most recent and advanced developments in the international and comparative law of human rights.

It is true that some countries, such as France, have liberalized their abortion laws since Roe v. Wade.28 But in the Federal Republic of Germany (BRD), the Federal Constitutional Court struck down the relaxed abortion provision of the Federal Diet's Fifth Law for the Reform of the Penal Code.29 That decision now constitutes an admissible case before the European Commission of Human Rights.30

The overall picture of fetal rights in the international and comparative law of human rights has become clear through a land-mark analysis by two French legal scholars. Alexandre Kiss and Jean-Bernard Marie.31 They point out, inter alia. that even though it is true that the fetus does not automatically benefit from all the protections and freedoms afforded by international conventions, nevertheless, since the fetus is part of the mother's body, it "benefits by way of the mother from the protections accorded to her-specifically including the right to life" (example: Article 6 of the United Nations Covenant on Civil and Political Rights, prohibiting the execution of the death penalty pronounced against a pregnant woman; the same principle would apply a fortiori to torture and to cruel or inhuman treatment).

Moreover, the most recent international human rights agreements show increasing sensitivity to and concern for the protection of the human person from the very moment of conception. Thus the (nonobligatory) Declaration of the Rights of the Child states in its Preamble that the child "requires appropriate juridical protection before as well as after birth." The American Convention of Human Rights, which entered into force in 1978, declares (Article 4) that

Every person has the right to have his life respected. This right shall be protected by law and, in general, from the moment of conception. No one shall be arbitrarily deprived of his life.

The United States has not ratified the American Convention, and the strong wording of this right-to-life article has worried more than a few congressmen: might not the United States, after ratification, find itself a defendant before the Inter-American Court of Human Rights because of Roe v. Wade?

Whether such a worry is realistic or not (and the U.S.-if it does ratify the Convention-may well take the coward's way out by qualifying its ratification of Article 4 by a "reservation" or "statement of understanding"), the American Convention sharply illustrates the tension between Roe v. Wade and the powerful trend toward maximizing human rights on the international scene. Just as there is a steady movement in municipal tort law toward giving a child wider legal opportunities to bring a cause of action to recover for negligently inflicted prenatal injuries32 - just as in the realm of prenatal torts viability is less and less regarded as a meaningful criterion for recovery-so on the international plane the rights of the unborn are gaining ground continually.

One may therefore hope that scientific knowledge, jurisprudential self-analysis, and concern for human rights will finally bring contemporary American law to its senses in the matter of the protection of the lives of the unborn.33

1. J. J. Osborn, The Associates (Boston: Houghton Muffin. 1979). pp. 212. 219.

2. Roe v. Wade, 93 S. Ct. 705 (1973) at 730.

3. Quoted in Norman Sheresky, On Trial (New York: Viking Press, 1977), p. 84.

4. J. H. Wilkinson III, Serving Justice (New York: Charterhouse Books. 1974), p. 74

5. Op. cit., Roe v. Wade. at 725, 731.

6. lbid., at 735.

7. Ibid., at 728.

8. Jules CarIes, La fécondation (Paris: Presses Universitaires de France, 1967). pp. 81-82.

9. Cf. J. W. Jones, The Nazi Conception of Law (New York: Oxford. 1939).

10. Dred Scott v. Sandford. 19 Howard 393 (1857)

11. Op. cit.. Roe v. Wade, at 733.

12. On the psycho-social dimensions of the abortion issue. see especially M. O. Vezina, Journal d'une avortée (Montreal: Editions La Presse. 1974t: K. Luker. Taking Chances: Abortion and the Decision Not to Contracept (Berkeley. Calif.: University of California Press, 1976): L. B. Francke. The Ambivalence of Abor-tion (New York: Random House. 1978).

13. Cf. M. L. Ernst and A. U. Schwartz, Privacy (New York: Macmillan, 1962): H. Gross, Privacy-Its Legal Protection (Dobbs Ferry. N.Y.: Oceana. 1964): 0. D. Glenn, "Abortion and Inalienable Rights in Classical Liberalism,' American Journal of Jurisprudence 20 (1975). 62-80.

14. Section III C 'Property Law") of the essay. "The Commencement of Life: An Historical Review," forthcoming in the Pepperdine University Law Review

15. E.g., V. M. Chkhikvadze. editor, The Soviet State and Law (Moscow: Institute of State and Law. 1969).

16. Cf. Jonathan Black, editor. Radical Lawyers (New York: Avon, 1971).

17. W. Holdsworth. A History of English Law, II. 3rd edition (London: Methuen. 1923), 78.

18. A. W. B. Simpson, An Introduction to the History of the Land Law (Lon-don: Oxford University Press, 1967), pp. 253. 261.

19. W. Blackstone, Commentaries, 2-4.

20. To be sure, one must never forget that Blackstone had the most profound effect on the education of American lawyers in the eighteenth and nineteenth centuries: see, e.g., J. S. Waterman, "Thomas Jefferson and Blackstone's Com-mentaries," in D. H. Flaherty. editor, Essays in the History of Earls' American Law (Chapel Hill. N.C.: University of North Carolina Press, 1969). pp. 45 -88.

21. J. Kent, Commentaries, 3 18-19.

22. Justinian Digest, 41.1.3.

23. R. D. Melville. A Manual of the Principles of Roman Law Relating to Persons, Property, and Obligations (Edinburgh: \V. Green. n.d.). pp. 213. 217.

24. J. Black, Black's Law Dictionary. 4th edition (St. Paul, Minn.: West, 1957), p. 997.

25. W. Kent, Memoirs and Letters of James Kent (Boston: Little. Brown and Co., 1898), p. 276. The Chancellor was, however, converted to evangelical Christianity before his death: "Of late years my views have altered. I believe in the doctrines of the prayer books, as I understand them, and hope to be saved through the merits of Jesus Christ. . . . I rest my hopes of salvation on the Lord Jesus Christ" (ibid.. pp. 276-77).

26. K. E. Digby, An Introduction to the History of the Law of Real Property with Original Authorities, 4th edition (New York: Oxford, The Clarendon Press. 1892), pp. 298-300.

27. Robert M. Byrn, "Goodbye to the Judeo-Christian Era in Law." America, June 2. 1973, p. 512. Hall v. Hancock may be found in 32 Mass. (Pick.) 2-5. 26 AD 598 (1834).

28. See J. H. Soutoul. Consequences d'une loi apres 600 jours d'avortements Iegaux (Paris: Table Ronde, 1977).

29. Cf. H. 0. J. Brown. "Abortion: Rights or Technalities? A Comparison of Roe v. Wade with the Abortion Decision of the German Federal Constitutional Court," Hunan Life Review, Summer 975. pp. 60-85.

30. X and Y. Against the Federal Republic of Germany. Application No. 6959/74. decision of 9 May 1967 (19 Yearbook. pp. 382-416).

31. Alexandre Kiss and Jean-Bernard Marie. "Le droit a la vie: rapport inridique." Human Rights VII (1974). 338-53

32. Cf M. L. Closen and J. D. Wittenberg. "Recovery for Preconception Negligence.'' Case & Comment. September-October 1979, pp. 34-38.

33. For additional jurisprudential analysis and critique of the current American abortion position. two readings are indispensable: R A. Destro, ''Abortion and the Constitut (mn: The Need for a Life Protective Amendment.'' California Law Review LXIII (1975). p. 1250: and J. T. Noonan. A Private Choice (New York: Free Press. 1979).

Taken from Slaughter of the Innocents, copyright 1981. You can order Slaughter of the Innocents for a total of $21 by calling the Issues, Etc. resource line at 1-800-737-0172.

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