The Public Policy
Casey v. Planned Parenthood

By Michael G. Smith

Chapter 5
The Casey Court and
the Perpetuation
of Violence in Society


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Legal abortion leads to further violence. In Roe v. Wade, the U.S. Supreme Court found that abortion was a privacy right.{121} However, the court was mistaken in finding that abortion is a private matter, because abortion is murder{122} and murder is never a private act. Rather, abortion is a public act that instigates further violence.

Abortion is a public act because abortion is killing,{123} and all killing is a public act. Accordingly, this public act is a part of the life of our society. As author John Leo has stated: "In the American tradition, the individual does not decide life-and-death issues. You donít get to buy your own electric chair, or start your own wars. Life and death decisions have always been social."{124}

The legalization of murder will lead to further violence in general. Legal abortion leads to more violence of a wide variety and every type because members of society have taken note that even a mother can intentionally kill her own children.{125} If that is true, then surely less ghastly acts of all types, such as assault, manslaughter, negligent vehicular homicide, are always permissible. As the German Supreme Court has stated: "We cannot ignore the educational impact [of legal abortion] on the respect for life."{126} The legalization of abortion murder teaches society that murder is an acceptable means to an end. As Mother Teresa of Calcutta has said, "Any country that accepts abortion is ... teaching its people ... to use any violence to get what they want." Moreover, a noteworthy murderer of late has indicated that abortion helped lead to the murder of her born children: Susan Smith, the mother who confessed to drowning her two young sons by in her car, said that an abortion she had undergone in high school was a strong factor in the murder of her children.{127} {128} {129} Furthermore, some women are clearly cognizant that a previous abortion later makes them feel violent.{130}

1. Abortion and Child Abuse.

More specifically, legal abortion can lead to abuse of born children.{131} There is a connection between what we can do to a baby in the first nine months of life, and thereafter.{132} Parents may unconsciously reason "I didnít have to have him. I could have killed him before he was born. So if I knock him around a little now that he is born, isnít that my perfect right.?"{133}

Abortion leads directly to child abuse by one or more of several very clear psychological mechanisms, as outlined by psychiatrist Dr. Philip G. Ney, head of the Department of Psychiatry at Royal Jubilee Hospital. These mechanisms are listed below:{134} {135}

Mechanism #1: "Abortion decreases an individual's instinctual restraint against the occasional rage felt toward those dependent on his or her care." Abortion contributes to child abuse through the suppression of the instinctual response of a woman to respond to a childís helplessness. "...The aborting person must suppress the species preserving instinct. Having done so once [through abortion], itís easier the next time [to suppress oneís natural inclination to treat children well]. The suppressed response is less effective, even when the helplessness is that of a whimpering child. Therefore, more people are responding to the cries of distress with rage or neglect, rather than protection...{136} An aborting woman, having brutally repressed her maternal instinct already, may have difficulty in restraining herself as she deals with any child, particularly a 'difficult' child.

Mechanism #2: "Permissive abortion diminishes the taboo against aggressing [against] the defenseless." There is no significant psychological difference between chopping up a child before it is born and 'knocking it around' after it is born.{137} After all, it is not the child that has intrinsic worth: Abortion defenders assert, "It's a choice, not a child."

Mechanism #3: "Abortion increases the hostility between the generations." Children of mothers who have aborted their own brothers and/or sisters may feel guilt and anger as abortion 'survivors,' and therefore display resentful, aggressive, or surly behavior towards parents, which in turn can trigger the adult's abusive behavior.

Mechanism #4: "Abortion has devalued children, thus diminishing the value of caring for children." Fifty years ago, parents were willing to (and very often did) undergo great deprivation for their children. Sometimes, parents would even willingly give their very lives to save their children. Now, children are seen as a source of deprivation. Our society, by its laws and attitudes, has given the green light to child abuse. Society is now beginning to hold that defective newborns are unworthy of life. As society does, individuals do; they are deciding that their children are somehow 'defective,' and therefore less worthy of life.

Mechanism #5: "Abortion increases guilt and self-hatred, which the parent takes out on the child." Many women have been shown to harbor strong guilt feelings over their abortions. "[D]etailed interviews find without exception [after abortion], there are feelings of guilt or profound regret [on the part of he woman]."{138} [quotations omitted]. Guilt is an extremely common cause of child battering and abuse.

Mechanism #6: "Abortion increases hostile frustration, intensifying the battle of the sexes, for which children are scapegoated." Many men directly or indirectly pressure women to have abortions, causing resentment and anger in the women. Many women abort against their husband's or boyfriends's wishes, thereby causing guilt and anger in them . This 'battle of the sexes' is many times directed towards the most helpless of bystanders -- their other children. These findings have been buttressed by Schoenfeld's and Barker's separate studies, which show that women who have aborted have much higher incidences of child abuse.

Mechanism #7: "Abortion truncates the developing mother-infant bond, thereby diminishing her future mothering capability." The establishment of the mother-infant bond is a delicate process and can be easily influenced by subtle changes in mother or infant. Bonding develops during pregnancy and becomes set when the infant is born.{139} Those who abort at any time during pregnancy interrupt a very delicate mechanism and sever the developing bond that is critical for the infantís protection against the motherís carelessness or rage. After an abortion, there are long-lasting psychological changes which make it more difficult for the same bond to develop in subsequent pregnancies.{140} The "...guilt{141} {142} {143} {144}{145}, self-hatred, low-esteem, and depression [following an abortion] can effect the bonding process..." with an unborn baby.{146} "It is generally recognized that an unresolved loss [through abortion] interferes with the process of attaching to a new child.{147} Accordingly, it is likely that abortion leads to bonding failure, an important cause of child abuse.{148} Furthermore, if a woman merely accepts the idea that abortion is proper, she has already artificially distanced herself from her child before birth -- even if the child is 'wanted.' When the mother/preborn infant bond is stunted in this manner, it is unreasonable to expect some kind of instant healing at birth. Not only does abortion harm the relationship of the mother and later born children, the 'pro-choice' attitude is destructive well beyond the prenatal period.

The above discussion shows that abortion can lead to child abuse of other children by the aborting woman. Accordingly, the National Center of Child Abuse and Neglect, reports that child abuse has increased more than 1,000 percent since abortion's legalization in 1973.{149} In addition, abortion, as murder, is also the ultimate abuse of the aborted child.

2. Abortion and Suicide.

Not only does abortion lead to more incidences of child abuse, but abortion also leads to greater incidences of suicide by post-abortal women. Meta Uchtman, Regional Director of Cincinnati Suiciders Anonymous, testified that, of the 4,000 women seen by her organization, 40 percent were post-abortal, far more than the 22 percent of women in general who attempt suicide.{150} This shows that there is a nearly 100% increase in suicide attempts by women after they have had an abortion. Various studies show that abortion increases rather than decreases the teen suicide rate. A study by Dr. Barry Garfinkel, head of the University of Minnesota's Child and Adolescent Psychiatry Department, surveyed 3,500 high-school teenagers to determine what factors in their lives contributed to depression, stress, and thoughts of suicide. The study found that girls who had abortions were four times as likely to attempt suicide as girls who had not aborted.{151} Another study, performed by Dr. Carl L. Tishler, found that teenaged girls who have had abortions are more likely to commit suicide on or near the anniversary of their abortions than at any other time.{152}

Legalized abortion teaches society that murder and other forms of violence are acceptable. More specifically, abortion leads to subsequent child abuse and suicide. As many Germans have realized in recent years, "violence must be confronted with a clear confession of the universal dignity of all human beings."{153} That is, the solution to violence is a recognition of the universal dignity of all human beings. "Human dignity must retain its validity without exception. Nor can it be revoked from a single human being. The mentally or physically handicapped, criminals, the unborn...all have right to this dignity.{154} When this necessary human dignity is ignored, as it is when the unborn are denied even the right to live, further violence is the natural result.


{121}410 U.S. 113, 93 S.Ct. 705.



{124}John Leo, Christianity Today (Oct. 7, 1996).

{125}Mother Teresa of Calcutta, in a speech at the National Day of Prayer breakfast before President Clinton, 1995.

{126}German Supreme Court, Feb. 1975, quoted in John Powell, S.J., Abortion: The Silent Holocaust 128 (1981).

{127}Boston Globe, Nov. 6, 1994.

{128}Eye On Washington, Portland Press Herald, Aug. 18, 1996, at 1C.

{129}Editorial, The Smith Case Highlights Abortion Fallacies, Chapel Hill Herald, Aug. 27, 1995, at 4.

{130}Barbara LeBow, Psychological Complications of Abortion (American Life League, Stafford, Va., 1986) (on file with author).

{131}Abortion, as murder of innocent unborn children, is child abuse in itself: the ultimate child abuse.

{132}Paul Ramsey, Princeton Ethicist, quoted in John Powell, S.J., Abortion: The Silent Holocaust 128 (1981).

{133}Harold O.J. Brown, Protestant Theologian, Death Before Birth (1977), quoted in John Powell, S.J., Abortion: The Silent Holocaust 128 (1981).

{134}Dr. Philip G. Ney, M.D., Abortion and Child Abuse: Which is Cause, Which is Effect? Address at conference on "Psychological Aspects of Abortion" sponsored by the Stritch School of Medicine, Loyola University, Chicago, Illinois (Oct. 31-Nov. 1, 1978) quoted in Dr. Brian Clowes, Pro-Life Encyclopedia Chapter 41 (American Life League, 1995).

{135}Dr. Philip G. Ney, M.D., Relationship Between Abortion and Child Abuse, 7 Can J Psychiatry 610-20 ( Nov. 24, 1987.

{136}Dr. Philip G. Ney, M.D., Infant Abortion and Child Abuse: Cause and Effect, in The Psychological Aspects of Abortion 26-27 (David Mall and Walter F. Watts, eds., 1979).

{137}Harold O.J. Brown, Protestant Theologian, Death Before Birth (1977), quoted in John Powell, S.J., Abortion: the Silent Holocaust 128 (1981).

{138}Ney, supra note 136, at 29.

{139}Id. at 31.

{140}Id. at 32.

{141}Francke, L.B., The Ambivalence of Abortion (1978).

{142}Kent, I., et al. 20 BC Med J 4 (Apr., 1978).

{143}Wren, B.G., Cervical Incompetence: Aestscogy and Management, Med J Aust 146 (Dec. 29, 1973).

{144}Dr. M.J. Buflin, "Deaths and Near Deaths with Legal Abortions," address at American College Of Gynecologists Convention (Oct., 1975).

{145}Drs. N.M. Simon and A.G. Sentuvia, Psychiatric Sequelae of Abortion, Arch Gen Psych 15 (Oct., 1966).

{146}Pam Koerbel, Does Anyone Else Feel Like I Do? And Other Questions Women Ask Following An Abortion 181 (1990).

{147}Dr. Phillip G. Ney, M.D., The Child and Death, 96 New Zealand Medical Journal 129, No. 726, (Feb. 23, 1983).

{148}Ney, supra note 136, at 32.

{149}Editorial, "Rhetoric against 'pro-lifers' contradicted by the facts," The Nashville Banner A18 (Mar. 14, 1996).

{150}Meta Uchtman, Regional Director of Cincinnati Suiciders Anonymous, in Sept. 1981 testimony considering parental notification before a minor's abortion, quoted in Suicide, Abortion and Parents, South Dakota Right to Life Newsletter 3 (Nov., 1981).

{151}Frontline Updates. "Suicide More Likely Among Aborted Teens" National Right to Life News 4 (Apr. 2, 1987).

{152}Carl L. Tishler, Ph.D., Adolescent Suicide Attempts Following Elective Abortion: A Special Case of Anniversary Reaction Pediatrics 670-671 (Nov., 1981).

{153}Wolfgang Huber, Bishop of the Protestant Church in Berlin-Brandenburg, Germany, and Professor of Theological Ethics at Ruprecht-Karls University in Heidelburg and General Editor of Dietrich Bonhoeffer Werks, The Unrelenting Assault on Human Dignity 5 (1996).

{154}Id. at 10.

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