tion chosen for any reason whatsoever, through the entire nine months of the pregnancy" (Arkes 47). From the extreme anti-choice view, life is said to begin at conception, and no matter what the reason for a pregnancy, abortion = murder. A mother's freedom of choice is "a cover for upholding the freedom to have an abortion, the basis for abortion-on-demand today, and it denies the freedom of the child to choose life" (Fowler 185).
A less extreme anti-choice view is the argument from potentiality. That is, even if the fetus is not a person from the moment of conception, it still has that potentiality of life, which increases with fetal development and which increasingly should not be violated as potentiality increases. Wennberg says that conception confers "a special inviolable status [which] is a product of divine purposes that are linked to one's natural capacity (potential or actualized) for spiritual and moral agency" (Wennberg, 1985, pp. 135-6). However, the question of when this "agency" emerges is problematic to abortion debate.
Roe v. Wade established fetus viability (although not guaranteed survivability outside the womb) at 24 weeks of pregnancy. On this ground, third-trimester abortions are not allowed except to save the life of a mother or in the case of extremely grave birth defects. This is the view that early-term abortion is less serious than late-term abortion, as is abortion owing to forcible rape, extreme maternal youth, or other mental incapacity. In former times, these reasons were presented to justify so-called therapeutic abortions even at early-stage pregnancies (Sullivan 42). In Planned Parenthood of Southeastern Pennsylvania v. Casey (1992), the Supreme Court reinforced the constitutionality of early-term abortions, before the fetus is at all "viable" outside the womb. In Leavitt v. Jane L., the Court struck down a Utah state law because it had prohibited abortions after 20, not 24, weeks (Calabresi 18).