"The woman is constantly aware for nine months that her body is not wholly her own: the state has conscripted her body for its own ends. Thus, abortion restrictions 'reduce pregnant women to no more than fetal containers.'"

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Statutes that curtail her abortion choice are disturbingly suggestive of involuntary servitude, prohibited by the Thirteenth Amendment, in that forced pregnancy requires a woman to provide continuous physical service to the fetus in order to further the state's asserted interest.

— Dawn Johnsen