AMY GOODMAN: Today, a Democracy Now! special. The Supreme Court appears poised to overturn abortion rights. Earlier this month, Politico published a leaked Supreme Court draft opinion which showed the court is set to overturn Roe v. Wade, the landmark decision that’s guaranteed federal constitutional protections of abortion rights for a half a century. If Roe is overturned, 13 states have so-called trigger laws that would make abortion illegal as soon as the court rules. Another 13 are expected to enact abortion bans soon after the court issues its ruling in the case known as Dobbs v. Jackson Women’s Health.

It was on the eve of the court’s oral arguments in the Dobbs case in November that law professor Michele Goodwin wrote a guest essay in The New York Times. It was headlined “I Was Raped by My Father. An Abortion Saved My Life.” I recently interviewed Michele Goodwin. I began by quoting from her article. A warning to our viewers and listeners: This segment includes descriptions of sexual violence.

AMY GOODMAN: “On Wednesday, the Supreme Court will hear oral arguments on the constitutionality of a 15-week abortion ban in Mississippi that provides no exceptions in cases of rape or incest. What’s at stake in this case matters to the countless girls and women who have been raped — including those who, like me, were raped by a father, an uncle or another family member.

“It was the early morning of my 10th birthday the first time that I was raped by my father. It would not be the last. The shock was so severe that I temporarily went blind before I began the fifth grade a few weeks later. By the time the school year began, my father had taken me to see a battery of doctors — a medical explanation would paper over the fact that the trauma caused by his sexual violence had caused my body to shut down.

“The physiological suffering that I endured included severe migraines, hair loss and even gray hair — at 10 years old. While other girls may have longed for puberty, I loathed the idea of it. My body became a vessel that was not mine. It had been taken from me. I lived in fear of the night, and the footsteps outside my bedroom door.”

Those are the opening words of Michele Goodwin’s New York Times guest essay last November headlined “I Was Raped by My Father. An Abortion Saved My Life,” again, written on the eve of the court’s decision that could overturn the constitutional right to abortion.

Michele Goodwin joins us now. She’s chancellor’s professor at University of California, Irvine School of Law, founding director of the Center for Biotechnology and Global Health Policy, and has written the book, Policing the Womb: Invisible Women and the Criminalization of Motherhood.

Professor Goodwin, welcome back to Democracy Now! We appreciate you joining us again this week. Can you start off by talking about why you chose to write that essay?

MICHELE GOODWIN: Amy, it’s important that we all understand that the new aspect of anti-abortion provisions includes an aspect that we would not have seen even five years ago. And that is that they make no exceptions for cases of rape or incest.

Now, these laws, on their own, are really quite chilling and horrific when we understand, just as a baseline, the importance of reproductive liberty and freedom and when we understand that a woman or girl is 14 times more likely to die by carrying a pregnancy to term than by an abortion in the United States. So, that’s just a baseline anyway. But then, when we add onto it that these laws have this kind of punitive aspect, as well, such that if you have been raped or that you have somehow survived incest, that you, too, may no longer have an exception that would provide for the ability to terminate a pregnancy, then we really understand that these laws have nothing to do, and they never have had anything to do, with protecting, respecting the autonomy, the dignity, the privacy of women or girls. In fact, they’re just simply cruel types of laws that are power plays that fit into a history of controlling women’s bodies and a history, quite specifically, of controlling the bodies of Black and Brown women. I mean, it’s been all women who have been subjected to the cruelties of such laws, but they have a particularly pernicious effect when we actually understand the historical implications, too.

As to rape and incest, I thought it was really important to legitimize that conversation and move us away from the taboo where we’re not supposed to talk about those things and where, clearly, the Supreme Court is not talking about that at all, as it was not raised in oral arguments. And in the leaked draft opinion that was circulated this week, Justice Alito does not even bother to actually mention rape or incest in any part of the nearly 100-page draft opinion.

AMY GOODMAN: When you talk about the health of African American women, also the mortality rate, maternal mortality rate of African American women, talk more — go more deeply into how these laws so deeply affect pregnant people all over the country, but particularly African American women and low-income women.

MICHELE GOODWIN: That’s right. I mean, as a general matter, we should all be horrified, because as a general matter, Black women are the canaries in the coal mine. What happens to them eventually reaches everybody else, though not always to the same degree. And that’s also been historically true, as well, as you look at states like Mississippi, Alabama, Texas.

You know, as a national matter, Black women are nearly four times more likely to die than white women by carrying pregnancies to term, three-and-a-half times more likely. But when you drill that number down and you actually peer under the hood and you look in states such as I’ve mentioned and you look even deeper within certain counties that have high populations of Black women, and you see then, well, in those places, Black women are five, 10, 15, 17 times more likely to die by carrying pregnancies to term than their white counterpart. And if you look at that national statistic that I gave you, that women generally are 14 times more likely to die by carrying a pregnancy to term than an abortion, well, in Mississippi, it’s over 100 times more likely to die — in fact, nearly 180 times more likely to die — if you’re a Black woman in Mississippi and you’re coerced into carrying a pregnancy to term. You’re that much more likely to die than by having an abortion.

And so, these alarming, really alarming statistics, that in any other category of health, if we heard that, the alarm bells would be ringing, and the government would be saying, you know, “Don’t choose the alternative at all. We want to keep you alive.” But what’s very interesting, when it comes to pregnancy and pronatalism in this country, it’s not about actually caring about the health of women, girls, people who can become pregnant. Not at all. Those alarm bells do not ring, even though the data that I’ve just shared with you comes from the CDC. It comes from the departments of health in these individual states. This is not data that’s being made up by people who are pro-choice. This is data that we’re getting from the governments in Florida, in Texas. This is Governor Abbott’s data that helps us to know that Texas is one of the most dangerous places in the entire developed world for a person to be pregnant.

AMY GOODMAN: I wanted to ask you about the Louisiana law — well, it’s not a law yet, it’s been proposed — that makes the destruction of a fertilized human egg at any stage of its development an act of murder, punishable presumably by Louisiana’s death penalty. I mean, this is astounding. You’re talking about — what about a person who works in a fertility clinic, who is holding a test tube —

MICHELE GOODWIN: Sure.

AMY GOODMAN: — with a fertilized egg and drops that test tube? Could they be charged with murder?

MICHELE GOODWIN: Well, this is where we’re in a space that I call the New Jane Crow, these laws that are not rational, they’re quite illogical, and, even more, they’re punitive, they’re cruel, they’re absolutely excessive. You know, if you think about the work of Pauli Murray, she was in many ways the godmother of the civil rights movement. Thurgood Marshall said that the book that she wrote on race laws was the Bible of the civil rights movement. And it’s about 800 pages, single-spaced, all of these crazy, really crazy Jim Crow laws, such as, you know, Black people can’t play checkers in the park — that ridiculous, that you think, “Who in the world thought of that?” — and would connect a fine and also criminal punishment if Black people are caught playing checkers in the park.

Well, in the New Jane Crow, we see laws such as and propositions such as what you’ve just described. They make absolutely no sense, but they’re absolutely cruel. And they’re meant to cause fear and to chill behavior. And their reach is beyond what we could grasp or even imagine. And that’s also really what Policing the Womb is about. It is a warning call, because we’ve already seen, again, as Black women in the canaries — canaries in the coal mine, we’ve seen that kind of punitive punishment, with Black women being dragged out of hospitals in shackles and chains in the late 1980s and '90s because they were imperfect in how they carried their pregnancies — no exact law saying that they could or should be dragged out of hospitals in such punitive ways — or giving birth in prison and on toilets and concrete floors. But the specter of policing their pregnancies, this kind of specter that the state owns everything with regard to your reproductive capacities, leads us into a space where there's dramatic surveillance. And it’s frightening for people. And that’s what these laws are meant to do. Yes, they’ll criminally punish, and possibly even death sentence, but they’re meant to instill fear in people.

AMY GOODMAN: I mean, you look at a most recent case that got a good amount of attention. It was the case of Lizelle Herrera. She is the Latinx woman in Texas who was charged with murder for, quote-unquote, a “self-induced” abortion. Now, because of groups like the Frontera Fund and women of color massively protesting, very much now that’s the exception to the rule. And she was released, and the charges were dropped. But if the Supreme Court rules as we think it will, based on this leak, this will become the rule, the rule of law.

MICHELE GOODWIN: Yes. Well, what we’ll see is just like in Jim Crow times or antebellum times. There are places where women can be free and girls can be free and may not have to worry. And even there, I would put some caution around it, because in California just a couple years ago, in the valley, there was a prosecutor who attempted to prosecute — in fact, was prosecuting — a woman for murder in the case of her stillbirth.

But, yes, what we will begin to see is that there will be states where people will not be free, where they will in fact be policed. And that kind of policing will also be connected to sex profiling, just like racial profiling — right? — this hyper-intensive look at what are girls and women doing with their bodies. There will be a turn to and pressure on nurses, on doctors, on medical staff to breach millennia-old practices of confidentiality between themselves and their patients. And they will breach that and will share that information, just as we saw in that case, with law enforcement. And then the next step will be arrest.

And this is not just simply anecdotal. As I record in my book, in the state of Alabama, already there have been hundreds of women who have come under the inspection of the state, charged and arrested under fetal endangerment — or child endangerment, in that case — laws, laws that would extend child, the definition of a child, to a fetus. And in Alabama, as I’ve mentioned, Black women, the canaries in the coal mine there, the majority of those women happen to be white. But they all are poor, or the vast majority of them are poor or working-class women, who have already come under the attention of the state in this prurient kind of way.

So what we have to understand is just what we’ve seen at the Supreme Court level, this attack that’s finally reached its pinnacle up to the Supreme Court to dismantle Roe v. Wade, this work has had tentacles. And it’s been working to criminalize women and also to impose civil punishments associated with pregnancy.

AMY GOODMAN: I wanted to ask you, Professor Goodwin, about the medication abortion, the pill. The L.A. Times’ lead story, “Abortion pills: A post-Roe game changer — and the next battleground.” The opening line, “The future of abortion in the U.S. is moving to the mailbox.” It’s also the front-page story today of The New York Times, “In Abortion Fight, Pills Could Be the Next Focus.” And it might surprise some people to know that more than half of abortions in the United States are result of taking these pills. You just did a podcast on this. Can you talk about this issue?

MICHELE GOODWIN: That’s right. That’s right. So, in Europe, this has been liberalized for decades. And due to political machinations and with the Food and Drug Administration, which at times can be captured by outside sources, it was stalled in the United States. But now, for more than a decade, just about a decade in the United States, we have a significant number of pregnancy terminations, abortions, being done through medication. They’re incredibly safe. The World Health Organization has compared an abortion to the safety of a penicillin shot. So these pills are very, very safe.

It’s worth noting that during the Trump administration, of over 22,000 drugs that one could receive in the mail during the height of COVID, medication abortion, these pills, were the only ones where a person had to go to a clinic, to a hospital, in order to receive them. So there is a way in which they’ve been selected out for a different kind of treatment than any other kind of prescription.

That said, they are accessible. And for people who are wondering now, women who are wondering now what comes next, well, these pills are accessible, and find a source where you are able to get them. And there are underground sources, as well, that are online, where folks are told this is how you order them, and they can be sent to a friend, and they can get them to you. There are a myriad ways of getting that done.

But the attack will be exactly that. The attack will come to the mailbox in order to try to shut down access to abortion in every means possible, including not just shutting down the clinics where surgical abortions can take place, but also searching the mailbox in some form of a way. So we’ll begin to see myriad laws being shaped that try to get at that, that makes it illegal to receive pills in the mail, that make it illegal to send pills in the mail, and any other. I mean, it’s amazing the kinds of innovations that these legislators can come up with to try to curb rights and dismantle rights. And they’re not very good and not committed to actually saving the lives of people who actually end up pregnant, want to stay pregnant or don’t want to stay pregnant.

AMY GOODMAN: Professor Goodwin, in your book, Policing the Womb, you write, “Arguably, abortion has become so fundamentally intertwined linguistically and conceptually with the terminology of 'reproductive privacy' and 'reproductive rights' that little else fits within the taxonomy. This is a mistake,” you write. Why?

MICHELE GOODWIN: Well, it’s been a mistake, when you think about the following. If you think about civil rights, that’s a plural. It has an “S” on it. And as having an “S” on it, it means that we’re not just talking about Brown v. Board of Education, right? We’re talking about education, employment, housing, the ability to swim in the pool in your neighborhood and walk through the park. We’re talking about accommodations in all of those areas.

And when we center just one aspect within abortion rights or within reproductive rights, then we’re talking just about abortion. Then we’re missing sex education, access to contraception. We’re missing conversations about sterilization. We’re missing all of everything else. And that kind of blind spot then means a failure to pay attention to many of the other areas where there have already been encroachments on reproductive health rights and justice.

And so, this is why we’ve missed largely what’s been happening to Black and Brown women, the kind of most horrific treatment by government during their pregnancies. This is how the agenda of personhood was missed in the 1980s and ’90s when it was being inflicted on Black women. You know, when prosecutors are claiming that your embryo or your fetus is a living born child — and it is not, by any constitutional definition — then everybody should be alarmed. But in the 1980s and ’90s, it completely missed those in the reproductive rights movement who were only focusing on abortion.

But here’s the other thing, Amy. Given the histories of coercion and coercive reproduction in the United States, that dates back to the forced kidnap and trafficking of Black women, then we should all be concerned about the fact that Black women, for centuries in this country, have not been accorded dignity when they are carrying pregnancies to term, and when they’re carrying pregnancies to term that they want. And we should want it all. We should want that women should be able to survive and have dignity when they are pregnant and want to be pregnant. And we should also care about government coercively forcing women to carry pregnancies that they don’t want, for the benefit of random state legislators that these women do not even know.

AMY GOODMAN: Michele Goodwin is chancellor’s professor at University of California, Irvine School of Law. When we come back, I ask about her book, Policing the Womb: Invisible Women and the Criminalization of Motherhood. Stay with us.

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AMY GOODMAN: This is Democracy Now!, democracynow.org, The War and Peace Report. I’m Amy Goodman, as I continue my conversation with Michele Goodwin, chancellor’s professor of law at the University of California, Irvine. I asked her about the leaked draft opinion to overturn Roe v. Wade, written by Justice Samuel Alito. In part of his ruling, Alito provides a list of anti-abortion laws from various U.S. states enacted between 1850 and 1919. When these laws were passed, women did not have the right to vote. Most African Americans were either legally enslaved or, after emancipation, subjected to racial terrorism and lynching at the hands of law enforcement and the Ku Klux Klan. In his rewriting of history, Justice Alito says traditions from these eras should dictate current law. I asked Professor Goodwin to talk about Alito’s argument and the history she tells in her book, Policing the Womb: Invisible Women and the Criminalization of Motherhood.

MICHELE GOODWIN: That’s right. It’s a very interesting cherry picking, the kind of selectivity that Justice Alito brings to this, which in so many ways is also completely alarming, alarming for the fact that it is not an accurate account. This draft opinion is stunning and alarming for what it omits. It is stunning for the citations that are chosen in it, and its also historical erasures. And that’s just to start, to just level start.

So, this period of time that he chooses to select ignores the period before, when abortions were not criminalized. The Pilgrims performed abortions. Indigenous people, on whose lands we are doing this program, performed abortions and all myriad form of healthcare. There were at that point not men running around with stethoscopes and lab coats. Obstetrics and gynecology was not even a field at the founding of the United States. This period that he talks about is a period that leads up to the Civil War. It is a period of time in which abortion, curiously, becomes criminalized because 100% — nearly 100% of reproductive healthcare was being done by women. About half of those were Black women, and then there were Indigenous women and white women. And these were the midwives. And the midwives — and if anyone thinks about it, well, that makes sense that 2,000 years ago there weren’t guys with stethoscopes and lab coats saying, “I’m your gynecologist.” It just simply did not exist, right? These were women doing the care and work for women.

But in a period of time leading up to the Civil War, obstetrics and gynecology slowly becomes a field. And there are men like Horatio Storer and Joseph DeLee, and then there had been Marion Sims, a notoriously terroristic gynecologist who experimented on Black women and failed to even provide them — denied them pain relief. Right? No anesthesia for them. He wrote in his autobiography, in fact, Amy, how he would have epiphanies in the middle of the night and then take his knives and other tools and literally cut into the bodies of Black women for his middle-of-the-night experimentations and epiphanies. He is considered the godfather of gynecology. A statue was erected in his honor in Central Park. But I digress.

But it’s those guys who helped to lead a movement against midwives. And the way in which this movement takes shape is to say, “Well, they’re doing something immoral, and that is abortion.” It was not about abortions; it was about monopolizing a field. And they were successful at leveraging themselves to be able to push midwives out of reproductive healthcare, take over this field for themselves. I mean, between that period of time that he quotes, that Justice Alito quotes, and the beginning of the 20th century, we go from 100% of reproductive healthcare being done by midwives to 1% at the beginning of the 20th century. And what was used to do that was to criminalize abortion. And these were very strategic doctors.

And I’ll just add one more point to it. This was also so deeply racialized, because they wrote about — their words, not mine — about how white women needed to use their loins and go north, south, east and west. It’s this collection of doctors who pushed for anti-immigration campaigns against people who were coming from Asian countries. It’s a period of our history that’s worth unpacking, not just for reproductive rights but for the racism and its intimacy with white supremacy.

AMY GOODMAN: Professor Goodwin, you write about policing and criminalization around abortion, but also around women who want to have children. Can you tell us the story, the highly disturbing story you describe in your book, of Marlise Muñoz in Texas?

MICHELE GOODWIN: Yes. I mean, when we think about this as, again, the plural of reproductive rights and begin to look beyond abortion, then we see the tactics that have been invested in by this anti-woman, anti-trans — and it’s all together, and with a very specific focus on Black and Brown women, but a reach that goes everywhere.

Marlise Muñoz was a healthcare worker. She was an EMT. And she had a brain aneurysm, and she was pregnant. She experienced brain death. Brain death is well defined, and has been well defined and accepted for half a century in the United States. At the period of brain death, a person who has a “do not resuscitate” order would then not be resuscitated, allowed for the body to physically die, and cremated or buried or whatever that person has decided, or the family members. But in Texas and in nearly three dozen states, there’s what are called medical exclusion laws. The name doesn’t necessarily tell us what substantively it does. Substantively, what it does is it takes away that kind of decision-making for a woman who is pregnant.

So, in Marlise’s case, when she was rushed to the hospital, the hospital officials decided that she should be on a life-sustaining treatment. Only she was brain dead. Marlise’s husband, Erick Muñoz, and her parents said, “We do not want her on life support. She is brain dead. We want to be able to, with dignity, have her life come to a close.” Twice, she was medically sustained. There was a tracheotomy that was performed. The hospital ultimately taped her eyes shut, because it put her on a bed that violently rocks back and forth. There were pro-life protesters that came to the hospital and protested outside, saying that medical science didn’t matter, that in a week Marlise would be alive.

For 62 days, Marlise’s body was forced to be an incubator for a fetus that was not developing well at all, and against the will of her husband and her parents. They actually had to sue the state of Texas in order for Marlise to be released from the hospital and taken off of life support. She was dead. It is incontrovertible that brain death is death in the United States — except now if you happen to be pregnant person, a pregnant woman. Then, brain death somehow, in these anti-abortion states, means something different. And it is a tragic case in Marlise’s case. Her father talked about how her skin had become so hard, her body had become so hard, it was like a mannequin, touching her. The stench was so severe that it was hard for people to come into the room. But this is what the state of Texas is seeking to normalize.

AMY GOODMAN: We’re talking with professor Michele Goodwin. The stories you tell in this book, like of Bei Bei Shuai in Indiana, an immigrant woman from China who attempted suicide. If you can tell us her story? She was pregnant, and the fact that she was charged with murder.

MICHELE GOODWIN: Days before Christmas a few years ago, Bei Bei Shuai was in a parking lot, and her boyfriend threw money at her and told her that he was going away and never wanted to see her again. Distraught, Bei Bei Shuai sought to kill herself. She got rat poison. And it’s interesting to note that for women in China who are attempting to commit suicide, it’s not unusual to use — turn to pesticides and things like rat poison. Well, she ate five — six packets of rat poison in order to kill herself.

She survived, because her friends found her, rushed her to the hospital, where doctors engaged in very aggressive treatments to try to save Bei Bei Shuai’s life and to also try to preserve and save the fetus, as well. Angel was her child that was born and survived for four days and then died. Doctors were not clear exactly why and how Angel died. Angel could have died because of the very aggressive life-sustaining treatments that they tried to provide. They didn’t know.

In any case, Bei Bei Shuai was charged with first-degree murder. The prosecutors in the state of Indiana sought over 40 years of incarceration for Bei Bei Shuai. They charged her with first-degree murder and also attempted feticide. At the time in which the laws for feticide were enacted in the state, legislators said this would never be used against women and that the purpose for them was actually to go after people, men, who beat up their girlfriends and wives during pregnancy. But that was not the case in Bei Bei Shuai’s scenario. And what’s interesting to note there, Amy, is that in the state of Indiana, it’s not a crime to attempt to commit suicide. It is not a crime. And yet prosecutors went after Bei Bei Shuai as a pregnant person because she attempted to commit suicide while pregnant.

And I want to just add one other piece to that, too, that really helps us to see just how cruel the punishment is. In years prior to that, in using this feticide law, prosecutors sought three years in connection with a woman being stabbed to death while pregnant by her boyfriend — three years in his case for what happened to the fetus. In a case involving a bank robber who robbed a bank and shot a teller in the belly twice, killing twins, it was five years. In Bei Bei Shuai’s case, 40 years. And I think that really helps to establish just what this policing means and how it is a very cruel and punitive turn towards control of women.

AMY GOODMAN: You also note, Professor Goodwin, that hospitals and hospital staff serve as surrogates of the state. I mean, I go back to the Lizelle Herrera case, the Latina woman in Texas who was charged with murder, who apparently went to the hospital and, they said, had — was dealing with a self-induced abortion. We don’t know the details exactly. But it was clearly people in the hospital who is believed were involved with talking to the state that got her charged. The charges were dropped, because the public was so outraged by what happened to her. And this was very recent.

MICHELE GOODWIN: That’s right. It’s another example. And it’s an important example as to how doctors and nurses have essentially become snitches for the state — not all doctors, but a significant enough number of them that in the state of Alabama they kind of have a hotline relationship with prosecutors in that state. And I know this because I spent time in Alabama interviewing prosecutors, in person and then also by phone, interviewing them as to: How are you coming to prosecute these women in your state connected with their pregnancies? And I was directly told it’s because of the relationships that have been formed and built with nurses and doctors.

And, of course, this is the backdrop of the case involving the dozens of Black women in South Carolina where the Medical University of South Carolina purposefully engaged in creating a dragnet with police and prosecutors so that they could explicitly and specifically target Black women who used crystallized cocaine during pregnancy. Now, for your audience to be clear, there is no statistical difference in terms of the rate of use of crystallized cocaine between Black women and white women at all. But the Medical University of South Carolina wanted to focus only on Black women. And, in fact, in their dragnet, which included dozens of women literally being dragged out of their hospitals or shackled and chained during delivery, there was only one white woman who was implicated in their large and official dragnet. And that was a white woman on whose medical chart one of the head nurses wrote “lives with Negro boyfriend.” And that was enough to get her lumped in with the Black women who were singled out for this kind of chilling and horrific treatment. And all of this is important to know, and all of this we would have seen, if in fact there were broader attention paid to reproductive rights as a plural, rather than as a singular item.

AMY GOODMAN: Professor Goodwin, at the end of your book, you write about a Reproductive Justice New Deal. Can you explain what your recommendations are?

MICHELE GOODWIN: Yes. We have to understand that in these times, nobody is really safe. This is really a backsliding of democracy. This is really a trampling of the rule of law in many ways. And if we had more time on it, we could talk about just how Justice Roberts fits into that. But I write about —

AMY GOODMAN: Please do.

MICHELE GOODWIN: OK. I write about a Reproductive New Deal as the urgency of these times in recognizing that we’re all vulnerable. People who are LGBTQ, as we see in Texas, have become vulnerable; in Florida, the “Don’t Say Gay” legislation, which is now sweeping across the country; the attacks on parents and trans children in Texas. In this Reproductive New Deal, I outline that there should be constitutional protections associated with the reproductive sphere, and, in fact, with just simply the human sphere. And I delineate what all of that means, step by step, much in relation to just the kind of arc that we’ve talked about on your show this morning. Across all of these areas, we need to think about protecting people who can become pregnant, and seeing those as fundamental constitutional rights all along. And we don’t have an Equal Rights Amendment. And this is a means of explicitly getting at these various areas in which legislators have sought to basically strip away any form of human dignity, privacy, autonomy and equality from anybody who has the potential to become pregnant. And we are largely talking about women and girls.

AMY GOODMAN: That’s Michele Goodwin, chancellor’s professor of law at the University of California, Irvine, author of the book Policing the Womb: Invisible Women and the Criminalization of Motherhood.