Advances in Applied Sociology
2012. Vol.2, No.3, 214-222
Published Online September 2012 in SciRes (
Copyright © 2012 SciRe s .
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
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.
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
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
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 ) .
Copyright © 2012 SciRe s . 215
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
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-
Copyright © 2012 SciRe s .
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
Copyright © 2012 SciRe s . 217
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.
Copyright © 2012 SciRe s .
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
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 ( 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-
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
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
Copyright © 2012 SciRe s . 219
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
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
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
Copyright © 2012 SciRe s .
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
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.
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