Freedom of Conscience is Freedom of Choice: Women’s Reproductive Needs, Rights, and their Therapeutic Implications

doi:10.4236/aasoci.2012.23028

Paper Menu >>

Journal Menu >>

Advances in Applied Sociology

2012. Vol.2, No.3, 214-222

Published Online September 2012 in SciRes (http://www.SciRP.org/journal/aasoci) http://dx.doi.org/10.4236/aasoci.2012.23028

214

Freedom of Conscience is Freedom of Choice: Women’s

Reproductive Needs, Rights, and their Therapeutic Implications

Carlos M. Del Rio

Southern Illinois University, Carbondale, USA

Email: delrio@siu.edu

Received June 28th, 2012; revised July 30th, 2012; accepted August 12th, 2012

Using reasonableness, we examine the U.S. Catholic bishops’ opposition to provisions of the Affordable

Care Act of 2010. Weaving contributions from theology, philosophy, and jurisprudence, we emphasize

the reasonable importance of mental health therapy for women within a relevant Catholic/Christian dia-

logue, particularly in the wake of the U.S. Supreme Court’s decision on healthcare. We principally iden-

tify socially imbedded factors that contribute to ending unwanted pregnancies, and argue that freedom of

conscience is indeed freedom of choice within which women’s reproductive needs lie under protections of

the U.S. Constitution. We recognize that Catholic tradition originates in the words and behaviors of Jesus.

Examining closely these actions toward women, we find no reasonable justification for the bishops’ posi-

tion against women’s freedom of conscience. We also discovered that revelation does not belong exclu-

sively to the bishops; truth continues to be revealed to all human consciences, and true freedom does not

allow for coercion/castigation of dogmatic import. We advocate for women’s ability to openly discuss

their struggles to meet their reproductive condundra and to deconstruct their sexual stereotypes in mental

health therapy. We provide crucial recommendations to augment choices for women’s reproduction co-

nundra, and incite the need for new epistemic frameworks to address the complexity of female sexuality.

Keywords: Freedom of Conscience; Freedom of Choice; Women’s Reproductive Needs;

Healthcare Provisions; Constitutional Protections

Synoptic Context and Purpose

The proposition that “all men are created equal” means that

all persons share an intrinsic human dignity and worth (Hen-

nette-Vauchez, 2011). It means persons have natural autonomy

which enables each to make decisions and to come together to

form lasting relationships, and communities. It means their

personal and communal interactions carry a sense of fairness

and retribution. And as individuals contribute to their commu-

nities, their communities protect their equality and their needs.

In principle, these are the essential characteristics of civil soci-

ety in our country.

Worldwide communities have recognized fairness and retri-

bution as constitutive of the reciprocity between persons and

their common good whether regional or global. These attributes

are essential to ethical principles (of respect, autonomy, justice),

and to jurisprudence (Torfs, 2011). Yet, because doing what is

ethical does not mean of necessity doing what is legal, and vice

versa; we suggest the nexus between these areas is doing what

is reasonable (that which is not intrinsically contradictory in a

logical sense). Simply proposing that all persons are “created

equal”, as human beings, does not capture the needs that dis-

tinguish their sexes. For example, men and women have dif-

ferent biological and health needs, particularly in terms of re-

production. They also have different ethical responsibilities

emerging from these sexual needs. Working complementarily

to one another among sexes is therapeutically and socially de-

sirable. It is unfortunate, however, to observe that when men

and women fail to understand one another, imbalances occur

and one sex usually oppresses the other. As we intend to ex-

plain below, sex (gender) politics and its social consequences

have been deleterious to women’s sense of sexual freedom

(John Paul II, 1995: § 3). Ethical advocacy compels us1, as

mental health therapists, to analyze how gender divisions su-

persede fairness a nd retrib u tion in our society.

With a compelling social interest, the Obama administration

enacted into law the Patient Protection and Affordable Care Act

of 2010 (House Office of Legislative Council, 2010). Its im-

plementation will go into effect in August, 2012. One of its

main effects is the provision of preventive healthcare for

women’s reproductive needs. This legislation originally re-

quired employers to absorb the cost of these preventive services,

but it met opposition from religious leaders, particularly from

the U.S. Catholic bishops (Ad Hoc Committee for Religious

Liberty [AHCRL], 2012).

The U.S. Catholic bishops claimed magisterial authority to

speak for “all” Catholic women, and, indeed, in the stead, of

“all” religious women in America against the provision of con-

traceptives, abortifacients, and sterilization (AHCRL, 2012).

The bishops invoked religious freedom in a civil society against

provisions of the Affordable Care Act of 2010. The Obama

administration, in turn, accommodated this religious objection

and placed the responsibility on insurance companies (instead

of religious employers) so that women could receive compre-

hensive healthcare at no cost (Federal Register, 2012). Yet,

unsatisfied with this accommodation, the U.S. Catholic bishops

designed a two-week campaign, the Fortnight of Freedom, be-

1Using editorial “we” is not encouraged in scholarly works. However,

because I wish both to engage the reader and speak as a mental health

therapist, my presumptions are (a) that the silent reader’s pronoun and mine

will fuse into “we” and “us” and “our” and (b) when I refer to mental health

therapists I wish to speak as one with all professionals who care for the

human psyche whether they may be counselors, social workers, psycholo-

gists, psychiatrists, physicians, and so on.

C. M. DEL RIO

tween 21 June 2012 and 4 July 2012 to stand against this “gov-

ernmental intrusion” that threatens their religious convictions

against birth control from contraception to abortion (Otterman,

2012). The bishops argued that the legislation’s provisions are

unconstitutional (AHCRL, 2012). Most interesting is to realize

that this campaign coincides with the U.S. Supreme Court’s

decision on the constitutionality of the Affordable Care Act of

2010 (see footnote nine).

Here, we focus on the group that remains voiceless (Ameri-

can women) and attempt to interpret their experiences based on

germane statistics. A scrutiny of preeminent publications that

helped shape family therapy since its beginnings in early 20th

century American culture revealed an absence of publications

regarding women’s reproductive needs. More specifically, we

conducted a search in the Journal of Marital and Family Ther-

apy (from the American Association for Marriage and Family

Therapy), The Family Journal (from the International Associa-

tion of Marriage and Family Counselors), and Family Process

(from the Family Process Institute) concurrent with the Obama

administration between 2008 and 2012. We not only looked at

each article published in these sources over the last four years,

but we also conducted searches within the same publications

regarding: birth control, contraceptives, abortifacients, abortion,

family planning, and Catholic Church. We used EBSO Aca-

demic Search Premier to search these terms as: subject matters,

words within abstracts, and key words authors provided for

publication; and our results confirmed an absolute absence of

literature on these matters.

We did find specific publications from other areas of science

that inform the current discourse on reproductive matters.

Hence, we decided to commence a dialogue on the ethical,

clinical, and theoretical implications that these matters may

beget for mental health therapists, particularly those dedicated

to serving couples and family clients. A sense of professional

advocacy and ethical principles of welfare and no harm, justice,

autonomy, and loyalty provide impetus to our discussion.

We intend to address these reproductive matters within a

Catholic framework given that the same hierarchy’s actions and

epistemic perspective have opened the door for this discussion.

We embrace reasonableness to engage in this discussion. This

requires contributions from theology, philosophy, and jurispru-

dence germane to Catholic epistemology. We hope to achieve

clarity as we draw language from each of these disciplines.

At the outset we recognize that pregnancies ought to end in

childbirth, and that fertilized human ova not only require male

chromosomes but also never become trees, rocks, or artefacts

(from Latin artefactum, human made), but human persons.

However, establishing a person’s right to life entails other pro-

tections to sustain such life; allowing life to merely exist does

not guarantee its quality as life but renders human existence as

mere survival. However, the ability to freely make decisions

about birthing new life and sustaining such new life is indeed

women’s major contribution to the common good, but we sus-

tain that women’s ability to bring life forth must also be bal-

anced with their ability to make personal or professional con-

tributions to society (Mortensen, Torsheim, Melkevik, & Thuen,

2012; John Paul II, 1995, § 3, 12).Thus, we examine the rea-

sonableness of the U.S. Catholic bishops’ opposition to preven-

tive healthcare for the reproductive needs of women. And we

strongly emphasize that the bishops have never spoken so

openly and with equal force about unemployment, illiteracy,

lack of health services, poverty, unequal income earnings, un-

stable lasting relationships, dysfunctional partnerships, special

needs, economic recession, familial disruptions from the war on

terror, violence whether emotional, psychological, or physical;

and many other factors that have thwarted women’s ability to

make free decisions about their reproductive and healthcare

needs and those of their offspring, whether that same offspring

may be unwanted, mistimed, or unplanned.

Preventive Healthcare versus Abortion

Incidence

The first decennial census data of the 21st century revealed

that of every 10 Americans, 6 are female and 4 are male. And

20% of 308.7 million Americans are females of reproductive

capacity between 15 and 44 years (62.4 million). However,

only about one in every 10 Americans is a female of legitimate

reproductive capacity (ages ranging from 20 - 39 years; 41.1

million). Data groupings at every four years do not allow for

ascertaining how many of these women (41.1 million) were

sexually active either in a “marriage” or in a heterosexual rela-

tionship, or how many women were specifically 18 and older

(U.S. Census Bureau, 2012a). Yet, these 41.1 million women’s

reproductive potentials (presuming 100% are fertile) seem to be

the U.S. Catholic bishops’ major concern regarding preventive

healthcare services.

We turn to religious adhesions to comprehend the extent of

women under the bishops’ magisterial authority. The most re-

cent American Religious Identification Survey of 2008 (U.S.

Census Bureau, 2012b) proved statistically representative of the

American population (two years prior to the census). This sur-

vey identified 76% of Americans were Christians, and 25%

were specifically Catholic. Applying these rates to the census

data, it is probable that about 12.5% of Americans in 2010 were

female Catholics, and twice as many were Christian but not

Catholic.

We must emphasize that women are primarily females and

then religious regardless of denomination. As females, women

are sexual beings and their sexual expressions must remain

their own free choice. We also posit that women wish to avoid

pregnancies rather than terminate them once they have begun

(Dixon & Nussbaum, 2011). However, birth control historically

includes abortion incidence despite efforts to increase the effect-

tiveness of contraceptives, and abortion incidence is a more direct

result of depriving women of contraceptives. It is most surprising

to realize that almost 50.0% of all pregnancies in America are

unintended2, and that an alarming 40.0% of all unintended preg-

nancies end up in abortion. Said differently, of every 10 pregnan-

cies, 5 are unintended, and of these, about 2 end up in abortion.

At a national scale, these rates represented 1.2 million abortions

in 2008. Of these many abortions 37.0% of the participating

women were Protestant, and 28.0% were Catholic (Guttmacher

Institute, 2011). These data do not account for the religious af-

filiation of these women’s male counterparts. Left with only fe-

male statistics, a couple questions arise: What reasons pressure

women to seek abortions? And what sort of female profile

2“Unwanted” pregnancies include those that happen when women did not

want them neither at the time they occurred, nor at any time in the future.

“Mistimed” pregnancies are those that happen when women would wel-

come them some time in the future, but not when they hap

ened. And

“unintended” pregnancies are those that are either unwanted or mistimed

(Wildsmith, Guzzo, & Hayford, 2010). Human reproduction’s complexity

includes also embryos lost before implantation, at a probable 50.0% rate

according to biologists’ estimates (Cornwell, 2 0 0 1 ) .

C. M. DEL RIO

emerges from abortion incidence?

Reasons to Seek Abortions

Laws do not prevent abortion; contraceptives prevent abor-

tion (Shah & Ahman, 2009). In fact, in other societies where

abortion is lawful it is negatively correlated with its incidence

(Potts, 1967). This negative correlation is reasonable because

where contraceptives are available, abortion incidence de-

creases. By contrast, unwanted pregnancies lead to increased

abortion incidence. And women’s choices include their own

sense of self-efficacy: whether they believe they are ready or

able (in cases where children already exist) to care for their

children. What is most disturbing is that women who seek

abortions have reported some overpowering reasons that in-

clude: (a) pressure from boyfriend, husband, parents, extended

family, friends; (b) un-readiness to start or expand their families

due to already existing responsibilities; (c) experience serious

medical problems or learned their fetus has severe abnormali-

ties; (d) experience personal crisis; (e) experience religious or

social stigma usually in the form of persistent guilt or shame; (f)

failed contraceptives or non-use of contraceptives due to chosen

or imposed religious beliefs; (g) lack marital status, separated,

divorced, widowed; (h) inability to support or care for a child;

(i) pregnancy resulted from rape or incest; (j) interference with

career or education plans; (k) live in abusive relationships

where victimization led to pregnancy; (l) fear of physical abuse

from parents/partners; and (m) fear of being ejected from their

family home due to pregnancy (Dudley, 2003; Finer, Frohwirth,

Dauphinee, Singh, & Moore, 2005). These reasons necessitate

no commentary. Instead we only report them for reflection.

Composite Female Profile

All religious denominations are represented in women who

engage in contraceptive practices, and, at times, in abortion.

However, abortion incidence includes primarily young women,

unmarried women, racial minority women, women living in

poverty, and women whose education is limited (Dudley, 2003).

This composite profile does not only exclude their male coun-

terparts but it does emphasize women’s dispossession and

powerlessness. These women do not have open access to con-

traceptives, and if they do, they do not have the experience to

use them, or fail to use them for fear of religious damnation

added to their religious sense of sexual guilt (Yip, 2010).

Other Contributing Factors: Women’s

Inequality

Women have practiced birth control methods since antiquity

(Bujalkova, 2007; Joffe, 2009). These methods have ranged

from coitus interruptus to infanticide predominantly of neonate

females, and males with perceptible congenital malformations.

Abortion incidence was also a part of birth control practices in

ancient cultures3. Women cared for women, unless women

were wealthy in which cases male physicians tended their re-

productive needs. Historians have documented male knowledge

of female bodies that is not exclusive of those who inhabit fe-

male bodies (Bennett, 2008; Green, 2008). In fact, beginning in

the Dark Ages and moving into Modernity, a male dominance

in obstetrics became prominent in England and in the U.S.

(Green, 2008).

Whereas birth control methods would seem to be a female

content area, birth control has been subsumed to male domi-

nance. These methods comprise from contraceptives, to aborti-

facients, to abortion in contemporary societies. But access to

these preventive methods (excluding abortion) is determined in

great part by political agendas that shape legal frameworks that

either allow or disallow women to access them. However, the

responsibility for human reproduction is placed on female sex-

ual partners, with total disregard of the male co-participants in

these processes whether their co-participation may be genital or

detached by virtue of reproductive technologies. Thus, women

remain relegated as responsible for birth control methods, but

truly they are not allowed complete autonomy over reproduc-

tive decisions.

As a result, if women seek abortion to end their pregnancies,

it is not only a personal moral issue, but (also) abortion per se is

a social, cultural, legal, and political conflict that needs to be

addressed communally because women do not conceive alone;

nor should they be responsible for the material costs of moth-

erhood (Jesani & Iyer, 1993). Ideally societies ought to recog-

nize that the care of children is a communal responsibility, but

women have been historically subordinated to male leadership

and economic solvency regarding reproduction policies and

preferential male progeny.

Material Hardships

Women who earn incomes lower than men strive to meet

their basic needs. And when children suffer material hardships,

societies (and bishops) ought to do something to end these

hardships. The crude reality is that no one cares when women

or children suffer the visible and not so visible signs of priva-

tions in our society or in other societies. People are not usually

magnanimous to the necessitous.

Material hardships may be either critical or serious. If critical,

individuals struggle to meet their basic needs. If serious, indi-

viduals lack “goods, services, and financial ability to maintain

employment and a stable, healthy home environment” (Bou-

shey & Gundersen, 2001: p. 20). Usually, income, education,

and family composition are variables associated with material

hardships (Heflin & Butler, 2012). For example, women who

enter into material hardship have more children in their homes.

These same women suffer poor health and domestic violence,

and their food insufficiency is associated to lower income and

lower education (for detailed statistics on material hardship, see

Heflin & Butler, 2012).

Many women of reproductive age survive at a level of mate-

rial hardship in our society. These women have to make tough

decisions to control their reproductive capacities, and it should

not be surprising to anyone that some of these women have to

choose to end their pregnancies because of their overpowering

material hardships.

3Birth control has also favored historically the birthing of males over fe-

males. This preference for male heirs was to ensure the political control o

regions, countries, kingdoms, and empires. In this way, a tacit notion o

patriarchy has remained embedded into the cultural fabric of societies.

These attitudes that have favored males over females have been preserved

through the centuries unto contemporary social groups across cultures.

These phenomena manifest themselves in terms of gender stereotypes, by

which motherhood is conflated with womanhood (Cuzack & Cook, 2009).

Where do material hardships come from? Are they the by-

product of young, promiscuous, females? Or are they, perhaps,

the results of stronger variables that have been imbedded in the

fibers of human societies? No one can deny that women earn less

than men in equal positions and with equal educational back-

216

C. M. DEL RIO

grounds. No one can deny that women are presumed responsible

for childrearing responsibilities. No one can deny that women

have historically been diminished as sexual objects. No one can

deny that there is female sexual trading which uses drugs to

ensure women’s dependency on their handlers. To compensate

for these social variables, it is imperative to protect women’s

right to control their natural ability for reproduction. This

means that ideally women must not be forced to make choices

(or choose from lesser alternatives) that violate their consci-

ences, such as in the case of critical or serious material hard-

ships. In this sense the conscience that must be protected be-

longs to voiceless women in our society.

Gender Stereo ty pin g

Human sexes seem to have been created to preserve their

species (Genesis, 1: 27-28; New International Version). This

presumes heterosexual sharing of chromosomes is essential to

preserve humanity, albeit methods of procreation have ad-

vanced to the extent that coitus is only sufficient and no longer

necessary for human fertilization. Reproductive technologies

have recast the notions of fertilization and of motherhood. For

example, in vitro fertilization and surrogate uterus usage have

supplanted the “biological” notion of motherhood.

Notwithstanding advances in reproductive technologies, his-

torical records evince that women have been linked to mother-

hood and that they have been perceived socially (and “by divine

ordinance”) as necessary “vessels” for human procreation (e.g.,

Bradwell v. Illinois, 1872: pp. 137-138; John Paul II, 1988: §

II.3). This is an example of how embedded gender stereotypes

remain in our culture, attributing to women certain roles or

functions by reason of their sexuality. As a result, women have

been stereotyped primarily as mothers (Cusack & Cook, 2009).

Motherhood, thus, places on women but not on men the expec-

tation to “prioritize childbearing and childrearing over all other

roles they might perform or choose” to perform during their

life-times (Cusack & Cook, 2009: p. 57).

Perhaps gender stereotyping ought to provide women with

recognition and deference (John Paul II, 1988, § II.4). By con-

trast, gender stereotyping has subsumed women’s autonomy to

men’s autonomy in social, political, and religious contexts. For

example, women have also been stereotyped as “weak and vul-

nerable”, and as “incompetent decision makers” (Cusack &

Cook, 2009: pp. 55-56). The former cements the legal fiction

that women need laws and restrictions to protect them from

themselves. The latter renders women as irrational and devoid

of an inherent capacity for moral agency, thus, justifying the

denial of birth control methods and family planning decisions.

When gender stereotypes become part of our cultural beliefs

and behaviors, women are put at a disadvantage and their ability

to exercise their freedom is nullified either overtly (by means of

laws or religious dogmas) or covertly (by means of adopting

social practices that are so autonomous that they become second

nature and are not questioned or challenged). In the end, once

gender stereotypes are in place, they become very difficult to be

eliminated or changed (Cusack & Cook, 2009). We believe gen-

der stereotyping must end lest women be denied their natural

equality to men from ethical and legal perspectives.

Freedom of Conscience is Freedom of Choice

Freedom is essential to human will. We adduce that free will

is the ability to choose among alternatives without constrains,

even at the level where alternatives may be reduced to the point

that they may seem not to exist (Svetlichny, 2012)—this is the

major argument of determinism,4 to place causality for one’s

choices on outside factors, thus denying human agency. With

few denominational exceptions (e.g., Lutherans and Calvinists

during the Reformation era) free will remains consonant with

Christian perspectives of human agency (Fischer, 2010). Free

will infuses human agency with moral value, because one’s free

willful choices are always for the purpose of doing something.

As a result, human actions build upon one another, and their

purposes and their consequences define the moral character of

each person. Human agency rests upon a sense of ought-ness

that requires each human being to wonder: What am I to do?

Who am I to become?

Ancient accounts of creation, including the Jewish story in

Genesis, make allusion to the human ability to make free deci-

sions as a gift that renders them in close likeness to their Crea-

tor/s (O’Brien & Major, 1982). The tacit argument in these

stories posits that if God is perfect and good, God has to respect

human’s free will; otherwise if God took away human free will,

then God would not be perfect and good. And this is an illogic-

cal conclusion. This is not acceptable in monotheistic religions.

Said differently, God is self-sufficient and completely perfect

and good. God creates out of goodness, and God’s perfection is

reflected in the created order. In this creatural realm, human

beings are similar to God because they have intelligence (which

seeks goodness and truth) and the ability to make free choices,

the ability to choose among alternatives for the purpose of do-

ing something or of becoming a particular kind of someone

(Wertenbroch, Vosgerau, & Bruyneel, 2007). In contrast, if

God controlled all humans’ actions, all the time; then, there

would be no goodness in God, nor would there be perfection

reflected in humans’ ability to make free choices. There would

simply be no point to human existence granted that whatever

one were supposed to do or to become were already predestined.

If this were the case, and because God is all good and perfect,

then human beings would be always good and always perfect.

There would be no room for morally negative actions, but be-

cause we experience morally negative actions or consequences

of such actions (Gisin, 2010), it follows that God does not con-

trol humans’ free will at all.

In this sense, God is pro-human-choice—because God re-

spects (out of God’s own perfection) every human choice that

has ever taken place or will yet take place. God’s omniscience

does not cancel out the human ability to decide one’s future by

the choices and actions in which one engages presently (e.g.,

Rhoda, 2007).

Freedom of conscience is pre-required for free will to infuse

4It would be impossible to consider all possible arguments about free will

and determinism in this discussion. Suffice it to say that if all human ac-

tions were truly determine d by factors outside human control, this reasoning

would go on ad infinitum, but this would simply be a logical fallacy be-

cause at some point in time someone had to make a choice to do something

to set all cau sal factors in mo tion. Further, if hu man agency were not ex is-

tent, then moral responsibility would not follow, and the notion of hell, for

example, would either be non-existent or God would be unjust for allowing

eople to choose hell through habitual actions, or habitual mindsets. Even

though we have no concrete evidence of hell, we have concrete evidence o

morally evil actions in humanity’s history. And moral evil is the result o

human agency (see Grisez, 1983, for a greater explanation of these complex

moral views). And because moral responsibility follows moral actions, we

conclude human agency’s existence. We encourage readers to become

familiar with other philosophical positions including Determinism,and

Compatibilism. Here, we only touch briefly on free will because it is con-

sistent with Christianit

C. M. DEL RIO

human agency. It is within one’s conscience that one is able to

capture goodness as truth; we become aware of what is intrin-

sically right or wrong. And the discernment that each person

invests in making decisions is procedural in nature (no matter

how small is the time it takes within one’s conscience—this

time may be so minute that the process may seem either spon-

taneous or simultaneous to a person’s actions). And the choices

that the person makes, which are further, conveyed through

explicit acti ons must also carry the same free nature.

In consequence, echoing moral scholars, freedom of con-

science is truly freedom of choice: It is the ability to decide and

to act as one pleases (Paul VI, 1965: § I.1; Grisez, 1983). Free

will is not an ontological reality, but an epistemic process of

moral consequences. And the actions that human agency makes

manifest may be indeed perceived as ontological realities.

The intrinsic human right to liberty is meant to protect every

person’s ability to agency, the exercise of her free will. Socie-

ties implement legal frameworks to protect and to ensure each

person’s ability to choose from available alternatives without

constrains. Yet the development of legal enactments and case

law (judicial decisions) tend to follow interactional patterns of

what works for individuals within societies (Katz, 2011). In this

sense, insofar as an unfair distinction between the sexes re-

mains in our culture; a lawful procuration of personal rights

remains untenable. For example, it is possible to establish a

person’s right to life while simultaneously allowing lawful

practices that may render that same person’s life a mere sur-

vival experience, full of material hardships, disabilities, or other

conditions that would render that person’s pursuit of “happi-

ness” untenable.

More specifically, despite the deplorable conditions in which

women strive to plan their families and manage their reproduc-

tion capacities, at times opting to end unwanted pregnancies;

influential (Christian) groups have compounded to the difficul-

ties women face when seeking safe abortions by supporting the

enacting of laws that would expose women to: (a) unwanted

vaginal probing prior to abortion (at their expense), (b) images

of their unborn fetus, (c) ultrasounds that would display heart

activity in the pre-aborted fetus, and (d) increasing taxes on

those who seek abortion. Worse yet, American pro-lifers have

argued that to overturn access to abortion, two goals must be

achieved. One, the definition of person must be recast to in-

clude unborn human beings, and, two, more conservative

judges must be appointed to the Supreme Court (Potts, 1967)5.

We leave the reader to draw her own evaluations on whether

these initiatives substantiate the notion of a civil society in

which freedom to choose is considered to be a constitutional

right for all.

In the case of women’s reproductive needs and their health

coverage, the U.S. Catholic bishops’ challenge has rested on the

notion of cost. To which the Obama administration accommo-

dated the right to conscientiously object to pay for birth control

provisions by religious employers because the bishops rejected

to pay for these provisions for women in their employment. As

a result, the administration shifted the responsibility to insur-

ance providers so that women’s reproductive healthcare needs

would meet licit coverage. This means the U.S. Catholic bish-

ops’ campaign against the administration is not based on the

constitutional protection of freedom to choose without con-

strains in a civilized society. It began as a denial to pay for the

costs of birth control methods germane to women’s sexuality

(Eisgruber & Sager, 2007). It has taken on the impression of

religious freedom to allow for their magisterial authority to

dictate what is sexually acceptable of women’s sexuality and to

disallow women to make free choices as matters of their indi-

vidual consciences as persons and as citizens (Katz, 2011). This

position is inherently contradictory and thus unreasonable. It is

an epistemic dichotomy.

Free Will Constrained

Dignitatis Humanae (Paul VI, 1965b) defined religious lib-

erty simply as “immunity from coercion in civil society” so that

each person may act of her “own judgment, enjoying and mak-

ing use of a responsible freedom” (Paul VI, 1965b: § I.1). This

declaration exhorted governments to establish legal frameworks

to protect religious freedom, which requires theological free-

dom. Herein lays the challenge of religious liberty: The U.S.

Catholic bishops wish to ensure freedom from coercion in civil

society, yet they also coerce those who believe in God to follow

their claim for an all-encompassing magisterial authority in

matters of human reproduction. In this sense, one’s freedom to

choose becomes a predicate of what the bishops define as sexu-

ally acceptable belying the ontic diversity of sexual identities

and heterosexual practices.

The bishops are called to serve the ecclesia which is com-

posed of each and every one who assents to God’s revelation in

the person of Jesus (Matthew 20: 26-27). Yet the Catholic

magisterium leaves no room for any individual to exercise her

conscience absolutely and freely (Paul VI, 1965b: § II. 3-4),

especially regarding religious matters relative to the person’s

own sexuality. As a result, people live with a sense of fear of

facing excommunication, the denial of sacraments6 because of

the limited alternatives from which individuals ultimately make

choices regarding their reproduction. How is then each human

5When this writing began in April, 2012, one question remained unan-

swered: What about the dates the bishops have selected to campaign against

the Afforda ble Care Act of 2010? It has become clear that the U.S.Supreme

Court is deliberating on the constitutionality of this legislation based on its

mandate to purchase insurance coverage, which would require religious

followers to pay the cost of services relevant to the reproductive needs o

women, parti cularly the provis i on of abortion, according to some arg uments

(Anderson, 2011; Reinhardt, 2012a, b). So it seems that the bishops’ insis-

tence to protect religious liberty has become an accountancy dispute for the

ulterior motive of instilling their magisterial authority in sexual matters.

The Supreme Court is composed of five Republican appointed justices and

four Democratic appointed justices. Should political views cloud issues o

law and constitutionality? Better yet, should issues of freedom and con-

science protection become expenditure matters? It remains to be seen how

the justices would rule on the healthcare mandate and germane questions

(Rovner, Totenberg, & Frick, 2012). However they may rule, this article

remains timely to address the reproductive needs of women openly in

therapeutic encounters (unless a lack of diagnostic code for such endeavor

may render such conversations uncoverable and illicit). We know for ex-

ample that inside trading in the U.S. markets is illegal. Yet, it seems (com-

parable to inside trading) the bishops have had inside knowledge that bene-

fits them . Fi rs t, their co ncern for religious li b erty began when Benedict XVI

alluded to threats to freedom ex cathedra. Second, the president of the U.S.

ishops commenced his declaration against women’s reproduction choices,

as the last consistory (of cardinals) was in the making; earning him and

some other prelates hierarchical promotions. Third, the bishops have had

inside knowledge of the chief justice’s efforts to have the Supreme Court

rule on the healthcare law within the period the bishops have called Fort-

night to Freedom. Doubtless the Supreme Court’s decision on the chal-

lenges that have been raised against healthcare provisions will impact the

nation’s interest to provide comprehensive healthcare to individual citizens

(Rovner, Totenberg, & Frick, 2012). Yet, the bishops’ efforts to influence

the highest court of the land must not stop our efforts to advocatefor

women as persons and citizens entitled to constitutional protections regard-

ing freedom of conscience, w hi ch imbues freedom of choice.

218

C. M. DEL RIO

person expected to act of her own judgment and free will from

any coercion if freedom suddenly is predicated upon the bish-

ops’ magisterium?7

Humanae Vitae (Paul VI, 1968) came to light against rec-

ommendations from the committee that participated in its

preparation/redaction (Greeley, 1979). Humanae Vitae essen-

tially posits that all forms of birth control (contraception and

abortion) are moral evils, and that all coitus must be open to

procreation, and denies the possibility of coitus outside mar-

riage. Procreation then is the proper end of conjugal coitus, not

pleasure.

However ethically desirable Humanae Vitae’s universal

axioms may be they remain untenable and contrary to current

sexual practices. For example, the axiom that “all conjugal

coitus must remain open to procreation” finds no absolute on-

tological corroboration because not all heterosexual coitus are

capable of procreation, sexual pleasure also brings couples

together in intimacy; and, not all sexually active couples are

married, able to marry, or wish to be married; or are willing to

procreate. As a result, Humanae Vitae has met several Catholic

groups’ dissent, yet it remains the official position on conjugal

sexuality. But perhaps the most damaging aspect to the univer-

sal procreation axiom is the endorsement of “natural family

planning”8, the only acceptable form of birth control the bish-

ops recognize and encourage.

Evangelium Vitae (John Paul II, 1995b) demanded respect of

every human life because every human life is the proper object

of God’s love, particularly the lives of the poor, the weak, and

the defenseless. And whereas Evangelium Vitae denounced

abortion and other forms of ending life once begun, it recog-

nized that in some situations where individuals experience in-

surmountable pressures and choose to end life, these very con-

ditions diminish the moral responsibility of the “coerced” or

limited choices under which individuals make morally wrong

choices9. As a result, and not content with these social pressures

(which are the true essence of a culture of death), Evangelium

Vitae demanded everyone’s commitment (including the bish-

ops’) to promote just legislation to alleviate the conditions that

pressure individuals to end lives, insisting that a lack of inher-

ent fairness (among the sexes) would place the will of the

stronger (the rich and, perhaps, influential Christians) over and

above the rights of individuals, particularly the poor, the weak,

and the defenseless.

According to census data, only minority births increased in

the U.S. population by 1.9 percent to 114.1 million or 36.6% of

the total U.S. population (FoxNews.com). Several questions

(open for discussion) arise from these data. Are minority

women more fecund than white ethnic women? Or is it that

minority women have more restricted access to birth control

methods than white ethnic women? Do papal restrictions on

birth control only apply to minority women? Doubtless many

perspectives may provide diverse answers to these questions.

However, mental health therapists must address these questions.

Including for example: How to address the sense of guilt and

shame that may accompany women for engaging in conscious

choices that on first sight appear to defy bishops? How can we

best serve the presenting emotional disturbances, mood disor-

ders, and other comorbid conditions following abortion (Charles,

Polis, Sridharab, & Blum, 2008; Coleman, Coyle, Shupin, &

Rue, 2008; Major, Applebaum, Beckman, Dutton, Russo, &

West, 2009; Kimport, Foster, & Weitz, 2011)? Where, when,

and how must women speak openly about the factors that are

concomitant to the gender stereotypes that women face as

wives, mothers, sisters, daughters, citizens, and persons?

Therapeutic Implications

As the U.S. Catholic bishops insist on religious freedom to

further perpetuate the stereotype of women as primarily moth-

ers, this insistence coerces women’s freedom to choose child-

bearing and childrearing, regardless of whether they wish to be

mothers, or professionals, or simply dignified individual per-

sons.

From the data that are available, it is clear that minority,

young women with minimal education face the most challenges

regarding their sexual expressions. As mental health therapists,

we must speak for these voiceless women and interpret their

message both in academia and in the therapeutic encounter.

Women must learn about their nature, their dignity, their limita-

tions, and their potentials. Certainly feminist perspectives have

emerged to modify our perceptions of women. But this fact

must not prevent all mental health therapists and scholars to

continue to be open about these concerns that must be ad-

dressed everywhere. We must learn from the bishops to speak

about women’s freedom strongly, assertively, but without

self-serving motifs.

The bishops’ magisterial authority originates in scriptures,

revelation, and tradition; summarily, in the words and actions

of Jesus. We must then as professionals become aware of the

historical importance of how Jesus treated women. From a

Christian perspective both the birth and the resurrection of Je-

6The bisho p s claim th ei r au t hority to deny sacra ments is r o o t ed in eccles i as -

tical tradition. In contrast, tradition originated with Jesus’ mandate to give

freely what they freel y received ( Matthew 10: 8). In this sense, the b ishops

have no authority to deny sacraments to anyone, because they did not gen-

erate the sacramental grace that Jesus freely intended for all human beings.

7Magisterial authority is presumed infallible (incapable or error). By con-

trast, history h as evinced that papal positions have contradicted one another.

The fallacious nature of infallibility rests on its disjunctive implications:

either something is infallible or it is not. And historical evidence has proven

that the church’s teaching authority is not always infallible (Pham, 2004).

Hence, magisterial authority is not infallible; infallibility is thus logically

false.

8This absolute axiom: “all coitus must be open to procreation” is contra-

dicted by the simultaneous endorsement of natural family planning. Natural

family planning is a birth control method perhaps no different than coitus

interruptus. The former allows ejaculations only during periods of time

when no ova ar e pr esen t; the l att er al lows for ejacu lat ion s out sid e th e ut erus

to prevent sperm to reach ova when present. The former is acceptable be-

cause ejacu latin g insi de the u terus would ap pear th at th at particu lar ej acula-

tion took place in an environment conducive to procreation despite the fact

that it was “intentionally” done when no ova were present for procreation to

occur. But the latter comprises the equivocal intentionality; both prevent

fertilizatio n of ova.

9Moral complicity is diminished in proportion to available alternatives for

choices; th at is to say, peo pl e who face l imit ed al tern ati ves to make mor all y

questionable choices face lesser moral consequences. For example, this

rinciple of moral proportionality applies to Joseph Ratzinger’s complicity

when he was “forced” to join Hitler’s Youth, and repaired war airplanes. I

these repaired-airplanes were then used to kill other human beings,

Ratzinger’s contributing “forced-repairs” would face lesser consequences,

albeit it successfully contributed to the extermination of Semitic people.

Another example of diminished complicity applies to Karol Wojtyla, who

used liberation theology toward his native Poland by making a historic

“liberating declaration” through the principle of solidarity (Cornwell, 2001:

. 52) which led to Poland’s freedom from Soviet oppression. However, he

disciplined Brazilian and Peruvian liberation theologians who wished to

address poverty conditions of the peo ple entrusted to their pastoral care, a nd

he consistently ignored the oppression of archbishop Romero from El Sal-

vador until this prelate was murdered (Kwitny, 1997) while cele

rating the

Eucharist.

C. M. DEL RIO

sus are the most important facets of human redemption. The

nascent Jesus needed a woman, and the resurrected Jesus chose

a woman to tell his story; in both instances women delivered

and conveyed Jesus to the world. Jesus deliberately chose

women despite the condition in which women lived in Jesus’

era. They were considered male property and not reliable wit-

nesses in licit proceedings (Daniel-Rops, 1962; Ketzer, 1978).

Yet Jesus made women a sine qua non instrument of his human

existence as well as his resurrection message. Time and again,

Jesus selected women to challenge his contemporary traditions

and to augment his redemptive mission. Perhaps Christians

today ought to learn from Jesus’ selection of women over men.

If we were to synthesize Jesus’ attitude toward women to teach

others what being Christian means, we may premise it by

claiming that where there is love, there is healing and forgive-

ness, but where there is no love, there is only condemnation and

ridicule.

Certainly Jesus never addressed women’s sexuality directly.

Yet he did choose to adduce to men’s co-participation in sexual

activities (John 8: 7). Jesus did not condemn or ridicule either

women or men for being sexually active (John 4: 18). Instead,

only once throughout his life, Jesus chose an unmarried, sexu-

ally active woman to reveal unequivocally his divinity (John 4:

25-26). We can only wonder what his message may mean in

today’s society.

In contrast to Jesus’ attitude toward sexually active and un-

married women, the bishops have argued that requiring reli-

gious employers to pay the costs of contraceptives, abortifa-

cients, or sterilization violates the constitutional protection for

religious freedom and it is similar to demanding “a kosher deli

to serve ham sandwiches.” This argument obviates the U.S.

Catholic bishops’ ignorance of women’s sexuality (United

States Conference of Catholic Bishops, 2012). It is insulting

and ignorant; it not only minimalizes women’s reproductive

conundra within the spectrum of the limited choices we have

discussed, it also singles women as beneficiaries of others’

fiduciary responsibilities for their contractual employment

benefits, (which is unreasonable because women have a prop-

erty interest to contractual employment benefits), and it also

demonstrates apathy (total lack of empathy and understanding),

and condemnation of women due to their sexualities.

This inchoate “kosher deli” argument reminds us of the mag-

isterium of 1st century Jerusalem who wished to condemn a

woman to death because she was caught in the very act of

adultery (but not the man). We wonder how the U.S. Catholic

bishops may learn from the words and actions Jesus displayed

on that occasion (John 8: 7-8). We also wonder how could the

bishops have conscientiously helped to prevent the pressuring

conditions adduced in Evangelium Vitae so that fewer women

in 21st century America would have to choose to end unwanted

pregnancies or to engage in birth control methods (see “reasons

for seeking abortion” above).

Conclusions and Recommendations

Here, we have striven to remain within Catholic thought

given that the U.S. Catholic bishops commenced this dialogue.

However, we presume because Catholic theology does contrib-

ute to Christian dogmas, this dialogue may be amenable not

only to Christians but also to other Abrahamic traditions in

America.

Christianity originated as a diverging sect from Judaism. It

proclaimed Jesus was/is the son of Yahweh. In particular the

Catholic magisterium’s authority draws from scriptures, tradi-

tion, and revelation; which originates in the words and actions

of Jesus. Turning to Jesus’ exemplary actions, we have discov-

ered that he exalted women against the traditions of his time.

Jesus never chose power, greed, or political ambitions. Instead

Jesus showed kindness, sensitivity, and compassion to women,

and treated them as equals to men, revealing only to a (five-

times-married, sexually-active, unmarried-childless) woman his

divinity (Girzone, 2009; Greeley, 2007; John 4: 26). These

signs comprised his ministry, his redemption, and his legacy.

Jesus manifested special interest in the weak, the poor, and the

defenseless (Matthew 5: 1-11; Matthew 25: 36-36). Women in

today’s society continue to live in these conditions, and remain

voiceless while Christianity conflates their womanhood with

motherhood, leaving out the men who share their sexuality.

Human nature is very complex. To claim that God could

have created a “better” world, or that humanity is intrinsically

“flawed” has tremendous theological and scientific implications.

It converts God’s creative actuality into mere potentiality, and

denies God’s perfection and goodness. The world as we know it

is just as God intended it to be, despite human errors. Herein

lies however the perfection of the created order: A natural ori-

gin that has the potential for self-edification, or (unfortunately)

self-destruction. But Jesus’ Spirit has remained with humanity

revealing truth to every human conscience (Paul VI, 1965a: §

I.2; Matthew 28: 18-20).

Under the guidance of the Spirit we have advanced beyond

what is written in scripture. But recognizing the Spirit’s guid-

ance requires humility to recognize, for example, that God ca-

res particularly for the weak, poor, and defenseless. It is the

hierarchy’s responsibility to care for these seemingly insignifi-

cant members of the human family (Matthew 25: 43-40). This

also requires reflection and constant prayer (Girzone, 2006).

We mean the kind of prayer that asks for nothing from God, but

that wonders what we each can do to bring about God’s equa-

nimous presence to earth (Luke 18: 9-14).

Because the Spirit informs every human conscience with

glimpses of truth and goodness, conscience in turn is the foun-

dation of free choices. We have adduced that freedom of con-

science is therefore freedom of choice, and licitly these are

human rights under constitutional protections in the 1st and

14th amendments in the U.S. Constitution. By contrast, moral

abstractions and religious dogmas will never amount to civil

law (Posner, 2002; Reynols v. U.S., 1878; Rowe v. Wade,

1973). Instead both theology and jurisprudence are built upon

human patterns of behavior and on contributions from philoso-

phy, anthropology, sociology, medicine, and all other forms of

science. Science (from the Latin scientia, knowledge and un-

derstanding) is perhaps the true nexus between jurisprudence

and theology that enables us to discuss women’s reproductive

needs under any healthcare provisions.

Essential to science are goodness and truth, which according

to Catholic understanding emanate from God’s own Spirit who

guides the Church (John 16: 5-16). Ultimately, there is much to

learn from Jesus’ words and actions (Paul VI, 1965a: § I.2).

The U.S. Catholic bishops’ campaign against the Obama ad-

ministration is aimed at taking away from women preventive

services for their reproduction needs. Catholic women employ-

ees remain silent about this legal debate because of fear of los-

ing both their modus vivendi and their share in the Eucharistic

meal (which is contrary to Jesus’ unequivocal mandate to share

220

C. M. DEL RIO

sacraments freely with everyone, see Matthew 10: 8). Statistics

have revealed that contraceptive measures are negatively corre-

lated to abortion incidence. Nevertheless women’s access to

contraceptives remains to be decided as a political issue by the

stronger and richer members of society, placing women’s free-

dom to choose outside the scope of civil and constitutional law.

We support women’s right to free conscience which is their

right to make free choices unburdened by any form of civil and

religious coercion (Paul VI, 1965b: § I. 4). As mental health

therapists we stand with women. We also remain loyal to

women’s rights, and respect their autonomy. We must provide

them with therapeutic privacy where they can openly discuss

their sexualities, their dreams, and interests. We recognize we

need women to theorize about women. With few exceptions,

only male scholars have developed the frameworks that consti-

tute the systemic therapeutic paradigm. We need more

women’s contributions about what is therapeutic for them, and

about their conceptions of God, their metaphysics beyond the

realm of motherhood, and their epistemologies about what is

licit regarding their sexualities and their reproductive choices.

We put forward crucial considerations to augment the spec-

trum of choices for women’s reproductive decisions including:

(a) ensuring women’s healthcare needs are provided for by

insurance companies; (b) ending discrimination of same-sex

couples and enabling them to adopt the potential children who

face potential material hardships but whose mothers remain

willing to bring their pregnancies to term (for the Church’s

position against human discrimination, see Paul VI, 1965b: § I,

7); (c) ending sexual identity discrimination and promoting

contraceptive use; (d) recognizing that motherhood and father-

hood must co-share child care responsibilities; (e) ending eco-

nomic imbalances and enforcing equal income laws; (f) study-

ing and addressing invisible disabilities that women may face;

and (g) recognizing that women wish to be educated in higher

education and promoting their accessibility accordingly . Essen-

tially, promoting equality among sexes in our society and in

close intimate relationships may not only decrease abortion

incidence, but it may also be instrumental in ending material

hardships in our society (Meehan, 2011).

Doubtless, either liberals or conservatives will react to what

is stated herein. Yet, however, unpleasant this discussion may

appear to be, we believe as mental health therapists that these

real issues pertaining to women’s sexuality must be addressed

openly.

We are not supporting dissent (or excommunication) but a

realistic dialogue within which we must welcome the complica-

tions concomitant with a contemporary epistemology of female

sexuality. Human ontology has deep implications ranging from

theology to jurisprudence and to therapeutic theory and practice.

The realities women face regarding their reproduction choices

and rights must be discussed without guilt or fear of excommu-

nication. These realities are not relativistic, functionalistic,

merely secularist, or in any way subject to minimization and

dismissal. Instead, these realities are complicated facets of hu-

man sexuality as originally created (Gene sis 1: 27). We believe

the self-corrective presence of conscience which is inherent to

human beings has contributed to the evolution of Christianity

over the last two millennia (Paul VI, 1964: § 7, 50). It is only

by embracing this ongoing revelation about what it means to be

human that we posit humanity may continue to remain an im-

age of its Creator.

We close with a simple parable (on 24 June, 2012).

Once, there was a group of persons who differed from one

another (by sex, religion, political affiliation, education, income,

and so on). They were arguing about their sense of freedom.

Next to them, there was a river and a cart full of non-persons,

entrusted to their care. But as they continued to argue, they

unattended the cart that kept filling up with non-persons; and it

continued to tilt over unto the river, and one or two (out of

every ten) non-persons fell into the river and drowned. Then,

there came a moralist, a dogmatist, and an attorney. They saw

what was happening. So they went and tried to rescue every

non-person who fell into the river, but as they saved, perhaps,

one non-person, another one or two non-persons would still

drown. Then, there came woman. Woman saw and understood

what was happening, but instead of helping the last three per-

sons, woman went directly to the source of the problem and

stopped it. And the non-persons did no longer drown, at least

not as many. Finally, then came the “neutral” justices, and they

changed everything.

REFERENCES

Ad Hoc Committee for Religious Liberty (2012). Our first, most cher-

ished liberty: A statement on religious liberty. Washington: United

States Conference of Catholic Bishops.

Anderson, R. T. (2011). Protected in law, cared for in life: The new

health-care act fails to support pro-life principles. First Things, 215,

41-45.

Bennett, J. M. (2008). Forgetting the past. Gender & History, 20, 669-

677.

Boushey, H., & Gundersen, B. (2001). When work just isn’t enough:

Measuring hardship faced by families after moving from welfare to

work (Briefing Paper). Washington, DC: Economic Policy Institute.

Bradwell, V. (1872) Illinois. 83 U. S. 130, 137-138 .

Bujalkova, M. (2007). Debate and education: Birth control in antiquity.

Bratisl Lek Listy, 108, 163-166.

Charles, V. E., Polis, C. B., Sridharab, S. K., & Blum, R. W. (2008).

Abortion and long-term mental health outcomes: A systematic re-

view of the evidence. Contraception, 78, 436-450.

Coleman, P. K., Coyle, C. T., Shupin, M., & Rue, V. M. (2009). In-

duced abortion and anxiety, mood, and substance abuse disorders:

Isolating the effects of abortion in the national comorbidity survey.

Journal of Psychiatric Research, 43, 770-776.

Cornwell, J. (2001). Breaking faith: The Pope, the people, and the fate

of Catholicism. New York: Penguin Putnam, Inc.

Cusack, S., & Cook, R. J. (2009). Stereotyping women in the health

sector: Lessons from CEDAW. Washington & Lee Journal of Civil

Rights & Social Justice, 16, 47-78.

Daniel-Rops, H. (1962). Daily life in the time of Jesus: An authentic

reconstruction of biblical Palestine and the day-to-day lives and

customs of its people. New York: Hawthorn Books Inc.

Dixon, R., & Nussbaum, M. (2011). Abortion, dignity and a capabilities

approach. Chicago Public Law and Legal Theory Working Paper

number 345. The Law School, The University of Chicago.

http://www.law.uchicago.edu/academics/publiclaw/index.html

Dudley, S. (2003). Women who have abortions. In Abortion facts,

National Abortion Federation. Retrieved from:

http://www.prochoice.org/about_abortion/facts/women_who.html

Eisgruber, C. L., & Sager, L. G. (2007). Religious freedom and the

constitution. Massachusetts: Harv a rd University Press.

Federal Register (2012). Administration. 29 CFR Part 2590. RIN

1210-AB44. Department of Health and Human Services. 45 CFR

Part 147. Group Health Plans and Health Insurance Issuers Relating

to Coverage of Preventive Services under the Patient Protection and

Affordable Care Act.

http://www.gpo.gov/fdsys/pkg/FR-2012-02-15/pdf/2012-3547.pdf

Finer, L. B., Frohwirth, L. F., Dauphinee, L. A., Singh, S., & Moore, A.

M. (2005). Reasons U.S. women have abortions: Quantitative and

C. M. DEL RIO

222

qualitative perspectives. Perspectives on Sexual and Reproductive

Health, 37, 110-118. doi:10.1363/3711005

Fischer, J. M. (2010). Precis of my way: Essays on moral responsibility.

Philosophy and Phenomenological Research, LXXX, 229-241. Riv-

erside, CA: Philosophy and Phenomenological R es e a rch, LLC.

doi:10.1111/j.1933-1592.2009.00320.x

FoxNews.com (2012). Minorities now surpass whites in U.S. births,

census shows. FoxNews.com, Po litics.

http://www.foxnews.com/politics/2012/05/17/minorities-now-surpas

s-whites-in-us-births-census-shows/#ixzz1yiKHt4pT

Girzone, J. F. (2006). My struggle with faith. New York: Doubleday.

Girzone, J. F. (2009). Jesus: A new understanding of God’s son. New

York: Doubleday.

Gisin, N. (2010). Are there quantum effects coming from outside space-

time? Nonlocality, free will and “no many-worlds”. Geneva, Swit-

zerland: Group of Applied Physics, University of Geneva.

Greeley, A. (2007). Jesus: A meditation on his stories and his relation-

ships with women. New York: Tom Doherty Associates, LLC.

Greeley, A. (1979). The making of the popes 1978: The politics of in-

trigue in the Vatican. Kansas City, KA: Andrews and McM eel, Inc.

Green, M. H. (2008). Gendering the history of women’s healthcare.

Gender & History, 20, 487-518.

doi:10.1111/j.1468-0424.2008.00534.x

Grisez, G. (1983). The way of the lord Jesus: Christian moral princi-

ples. Chicago: Franciscan Her ald Press.

Guttmacher Institute (2011). Abortion. Fact sheets: Facts on induced

abortion in the United States.

http://www.guttmacher.org/sections/abortion.php

Heflin, C. H., & Butler, J. S. (2012). Why do women enter and exit

from material hardship? Journal of Family Issues. Published Online

11 April 2012. doi:10.1177/0192513X12442822

Hennette-Vauchez, S. (2011). A human dignitas? Remnants of the

ancient legal concept in contemporary dignity jurisprudence. Oxford

University Press and New York University School of Law, 9, 32-57.

House Office of Legislative Counsel (2010). The patient protection and

affordable care act of 2010.

http://housedocs.house.gov/energycommerce/ppacacon.pdf

Jesani, A., & Iyer, A. (1993). Women and abortion. Economic and

Political Weekly, 27 November 1993, 2591-2594.

John Paul II (1995b). Evanvelium vitae.

http://www.vatican.va/holy_father/john_paul_ii/encyclicals/documen

ts/hf_jp-ii_enc_25031995_evangelium-vitae_en.html

John Paul II (1995a). Letter of Pope John Paul II to women. Boston: St.

Paul Books and Media.

John Paul II (1988). Muli eris d ignit atem.

http://www.vatican.va/holy_father/john_paul_ii/apost_letters/docum

ents/hf_jp-ii_apl_15081988_mulieris-dignitatem_en.html

Joffe, C. (2009). Abortion and medicine: A sociopolitical history.

Management of Unintended and Abnormal Pregnan cy , 10, 1-9.

doi:10.1002/9781444313031.ch1

Katz, S. N. (2011). Family law in America. New York: Oxford Univer-

sity Press.

Kertzer, M. N. (1978). What is a Jew? New York: Collier Books.

Kimport, K., Foster, K., & Weitz, T. A. (2011). Social sources of

women’s emotional difficulty after abortion: Lessons from women’s

abortion narratives. Perspectives on Sexual and Reproductive Health,

43, 103-109. doi:10.1363/4310311

Kwitny, J. (1997). Man of the century: The life and times of Pope John

Paul II. New York: Henry Holt and Company.

Major, B., Applebau m, M., Beckman, L., Dutton, M. A., Russo, N. F.,

& West, C. (2009). Abortion and mental health: Evaluating the evi-

dence. American Psychologist, 64, 863-890.

doi:10.1037/a0017497

Meehan, M. (2011). Why should liberals defend the unborn. Human

Life Review, 15-30.

Mortensen, O., Torsheim, T., Melevik, O., & Thuen, F. (2012). Adding

a baby to the equation. Married and cohabiting women’s relationship

satisfaction in the transition to parenthood. Family Process, 51, 139.

doi:10.1111/j.1545-5300.2012.01384.x

O’Brien, J., & Major, W. (1982). In the beginning: Creation myths

from ancient Mesopotamia, Israel and Greece. The American

Academy of Religion. Number 11.

Otterman, S. (2012). Dolan says Obama policies threaten “Sacred Lib-

erties”. The New York Times, NY/Religion.

http://www.nytimes.com/2012/06/23/nyregion/obama-mandate-threa

tens-sacred-liberties-dolan-says.html?ref=health

Paul VI (1968). Humanae vitae.

http://www.vatican.va/holy_father/paul_vi/encyclicals/documents/hf

_p-vi_enc_25071968_humanae-vitae_en.html

Paul VI (1965b). Dignit a t is humanae.

http://www.vatican.va/archive/hist_councils/ii_vatican_council/docu

ments/vat-ii_decl_19651207_dignitatis-humanae_en.html

Paul VI (1965a). Dei verbum.

http://www.vatican.va/archive/hist_councils/ii_vatican_council/docu

ments/vat-ii_const_19651118_dei-verbum_en.html

Paul VI. (1964). Lumen gentium.

http://www.vatican.va/archive/hist_councils/ii_vatican_council/docu

ments/vat-ii_const_19641121_lumen-gentium_en.html

Pham, J. P. (2004). Heirs of the fisherman: Behind the scenes of papal

death and succession. New York: Oxford University Press, Inc.

Posner, R. A. (2002). The problematics of moral and legal theory.

Cambridge, MA: The Belknap Press of Harvar d University Press.

Potts, M. (1967). Legal abortion in Eastern Europe. Eugenics Review,

59, 232-250.

Reindhardt, U. E. (2012). Awaiting the Supreme Court’s healthcare

ruling. The New York Times, Economix: Explaining the Science of

Everyday Life.

Reindhardt, U. E. (2012). The Supreme Court and the national conver-

sation on health care reform. The New York Times, Ecomix: Ex-

plaining the Science of E veryday Life.

Reynolds v. U. S., U. S. 14 5 (1878).

Rhoda, A. (2007). The philosophical case for open theism. Philosophia,

35, 301-311. doi:10.1007/s11406-007-9078-4

Rovner, J., Totenberg, N., Frick, A. (2012). Countdown to the Supreme

Court’s ruling on health care. National Public Radio. Weekend Edi-

tion Sunday.

Rowe, V. Wade, 410 U. S. 113 (1973).

http://www.npr.org/blogs/health/2012/06/24/155596355/countdown-t

o-the-supreme-courts-ruling-on-health-care

Shah, I., & Ahman, E. (2009). Unsafe abortion: Global and regional

incidence, trends, consequences, and challenges. Journal of Obstet-

rics and Gynaecology Canada, 31, 1149-1158.

Svetlichny, G. (2012). How free will could will. History and Philoso-

phy of Physics, 1-11.

Torfs, R. (2011). The internal crisis of religious freedom. International

Journal for Religious Freedom. 4, 17-27.

U.S. Census Bureau (2012b). U.S. statistical abstract, 2012.

http://www.census.gov/compendia/statab/

U.S. Census Bureau (201 2 a ). 2010 Census d at a .

http://2010.census.gov/2010census/data/

United States Conference of Catholic Bishops (2012). Bishop Lori tells

parable of the kosher deli and the pork mandate in congressional tes-

timony, 16 F e bruary 2012. Conscience P rotection.

http://usccb.org/issues-and-action/religious-liberty/conscience-protec

tion/index.cfm

Wertenbroch, K., Vosgerau, J., & Bruyneel, S. D. (2008). Free will,

temptation, and self-control: We must believe in free will, we have

no choice (Isaac B. Singer). Journal of Consumer Psychology, 18,

27-33. doi:10.1016/j.jcps.2007.10.006

Wildsmith, E., Guzzo, K. B., & Hayford, S. R. (2010). Repeat unin-

tended, unwanted and seriously mistimed childbearing in the United

States. Perspectives on Sexual and Reproductive Health, 42, 12-22.

doi:10.1363/4201410

Yip, A. K.-T. (2010). Special feature: Sexuality and religion/spirituality.

Sexualities, 13, 667-670. doi:10.1177/1363460710384555