By Daniel Becker, President, Personhood Alliance
“Many seek the face of a ruler, but it is from the Lord that a man gets justice.”
“Not from the stars do I my judgment pluck . . .
. . . not to tell of good or evil luck . . .
Nor can I fortune to brief minutes tell,
Or say with princes if it shall go well.”
William Shakespeare, Sonnet 14
For over a generation, the pro-life movement in the United States has awaited a propitious alignment of the political stars and built an entire strategy around it. This strategy demands a President who will appoint pro-life Supreme Court Justices, a U.S. Senate majority that will approve those Justices, a U.S. House and Senate that will pass legislation “protecting the babies,” and a President who will sign these long-awaited bills, which will stand up to Supreme Court challenge. For over 40 years, we have anxiously waited. We may now live in that much-anticipated day of celestial political alignment.
Many hope that President Donald Trump’s election, Republican majorities in both houses of Congress, and a future conservative Supreme Court will bring about sustainable federal legislation and the overturning of Roe v. Wade. Realistically, this would return the power to legislate or prohibit abortion to the states, which have an overwhelming majority of Republican governors and state legislatures. Is this a realistic expectation? One would think so. After all, this has been a strategic objective for roughly 35 years. However, this strategy has several flaws that could subvert immediate and substantial changes in our laws to protect the preborn.
The strategy places too much faith in a political party and the political process. Both are subject to pressures that work against us. Too often, politicians take the path of least resistance, prioritize fiscal issues over life issues, and use, then ignore the pro-life base. But more importantly, this strategy forces the pro-life movement to abandon its role as a standard-bearer. As a consequence, the movement’s prime objective becomes electing Republican majorities in order to create the desired alignment—that is, choosing the role of king-maker. We only need to look at our history to see what has already resulted.
By advancing politicians to achieve a partisan majority, the pro-life movement deferred its objectives. Pursuing a lesser goal of electing a majority undercut the movement’s principled position of standing for all preborn lives. We have seen this when Republicans, who were endorsed and elected as “pro-life,” become resistant or even hostile to life issues when a principled stand for innocent life is required.
Not all of the pro-life movement has agreed with this strategy over the years. Some have adhered to a different perspective and plan of action. Faith, we are told, is only as good as its object. For decades, as a political action director and lobbyist, I dealt with self-described pro-life politicians and lawmakers. My experience proved to me that trusting their fidelity to the cause does not yield meaningful laws that protect the most vulnerable. How often have solidly pro-life politicians wilted under the pressures of legislative leaders who added deadly exceptions to pro-life bills? Instead, firm consequences are required to secure genuine progress.
Unfortunately, in recent years, mainstream pro-life leadership itself has demanded a flawed, depreciated standard. When leaders promote or accept deadly exceptions for rape, incest, or fetal anomaly, they contradict the movement’s foundational premise that every innocent human being is precious and deserving of protection.
An example of this contradiction is the Family Policy Alliance’s Statesmen Academy, a Christian program that “educat[es] politicians in the practice of effective politics to carry on the fight for godly values.” This training program is a partnership between Clarke Forsythe, President of Americans United for Life, and Tom Minnery, former Senior Vice President of Public Policy for Focus on the Family. When I met with Tom Minnery, he confirmed that the Statesmen Academy program includes teaching political prudence. When asked specifically if that meant teaching lawmakers to vote, when necessary, for these deadly exceptions he said, "Yes". Unfortunately, the Statesmen Academy’s “unwavering principles” only extend to some preborn children. This is no small matter. Proverbs 25:26 states, “Like a muddied spring or a polluted fountain is a righteous man who gives way before the wicked.” God exhorted the nation of Israel to root out sources of pollution:
“Beware lest there be among you a root bearing poisonous and bitter fruit, one who, when he hears the words of this sworn covenant, blesses himself in his heart, saying, ‘I shall be safe, though I walk in the stubbornness of my heart.’”
The Personhood movement has long-stood against this tide of compromise, and in this very book, is calling for a rejection of “poisonous and bitter fruit” and a return to first principles. We are often accused of “insisting on perfection,” “being 100%ers,” “being willing to let millions of babies die,” and even “siding with Planned Parenthood.” Yet, the accusers’ websites, emails, donor letters, and social media posts never acknowledge the departure from their stated missions. They continue to proclaim they are fighting to protect and defend “the right to life of every innocent human being from the beginning of life to natural death.” 
The alternative approach is to uphold a biblical sanctity-of-life standard in principle and strategy, in endorsement and communication, and in legislation and fundraising. If all of the pro-life movement embraced standard-bearing instead of king-making, the power of the grassroots would be unleashed. Politicians need pro-life voters. We deliver the margin of victory in many races. If we demanded a principled approach, the half-hearted moderates would have to change, or they would lose their pro-life constituencies. Later in this chapter, I provide examples of two states where this principled approach produced tremendous results.
Exceptions Undercut the Ground We Stand Upon
Either all innocent human beings are worthy of protection, or they are not. Abortions based on the manner of conception are as much a violation of the sanctity of life as those based on inconvenience, familial situation, school and career plans, or financial challenges. A child who is conceived in rape or who is disabled is just as human, just as capable of pain, and just as innocent as any other preborn child. Why are they not worthy of the same protections? Or, have they simply become bargaining chips for political gain?
A more difficult question arises: Is “pro-life” an accurate designation for those who embrace exceptions? Consider that God’s moral law clearly commands “nor shall children be put to death because of their fathers [sin].” In what other context do we legalize killing the innocent child for the crimes of the father? None. We call it murder. In what other context do we legalize killing the innocent child just because he or she is disabled? None. We call it murder. Within this logical framework, then, is it not accurate to say that those who embrace exceptions also embrace “murder of innocents by statute?” This is a difficult message to hear. But consider that the entire premise of the pro-life message is destroyed by exceptions.
All preborn children are worthy of life, not just some. Every innocent human being deserves protection, from life’s beginning until natural death. The Personhood movement embraces the preciousness and worthiness of every human being because each bears God’s own image, regardless of the manner of conception, disability, the degree of dependency, or any other feature of existence. Let us look at another way that biblical personhood becomes compromised by politics.
A Deadly Message Bill
A message bill is a bill that is not expected to become law, either because there is an insufficient support to pass it in one or both chambers of Congress or because, if passed, it will be vetoed by the President. Message bills are strategic in nature, in that they educate and shape the public dialogue and debate. At the very least, a message bill energizes, informs, and equips our base and our own lawmakers as to the consequences of violating the sanctity of life. A message bill always includes some measure of instruction that is intended to flag future legislative objectives. Therefore, it is imperative that we do not send a mixed message that lays the groundwork for future defeat. In this way, the Pain-Capable Unborn Child Protection Act of 2015 (H.R. 36) failed on several counts. Its saga is illustrative of king-maker pragmatism sabotaging our role as standard-bearers.
Indeed, the message of the pain-capable approach is instructive. It teaches that preborn children of 20 weeks gestation feel pain. This focuses the discussion on the defenseless child and engenders a visceral reaction to the barbarity of abortion. It highlights the humanity of the child and her need for protection. However, it fails to extend those protections for children younger than 20 weeks gestation. Personhood Alliance prefers a message bill such as the Sanctity of Life Act, which establishes our end goal even though it may seem unattainable at present. Nevertheless, let us explore the history of the pain-capable effort and why it failed.
How the Message Became a Mess
Three successive Pain-Capable Unborn Child Protection Acts were introduced in 2012, 2013, and 2015. In each case, the promoters knew the Senate would filibuster the bill and stop it there. If it were somehow to pass the Senate, President Obama promised to veto it. The bill had no chance of becoming law and did not provide any way to save any children, but the educational and political potentials were excellent.
Pro-life stalwart, Representative Trent Franks of Arizona, introduced the first bill, H.R. 3803, with no exceptions in January 2012. The bill applied only to the District of Columbia. It passed the House but failed to get the two-thirds majority required under Senate rules.
In 2013, Representative Franks introduced the bill again as H.R. 1797. On a Friday, the Judiciary Committee expanded its scope to apply nationwide and voted down proposed amendments that included rape, incest, and health of the mother exceptions. The bill passed the full committee to be taken up by the House. In the days that followed, Congressional leaders held meetings with congressmen and representatives of national pro-life organizations. As is often the case, many “pro-life moderates” refused to vote for a bill that did not include deadly exceptions for rape and incest. When the bill came to the House from the Monday Rules Committee meeting, it included those deadly exceptions. That Tuesday (June 18, 2013), it passed the House, but as expected, the Senate refused to take it up.
In the fall of 2014, national pro-life organizations and their pro-life counterparts in Congress held meetings to discuss the pro-life strategy for the next Congress. On January 6, 2015, Representative Franks introduced H.R. 36, the third Pain-Capable Unborn Child Protection Act. This time, appallingly, it included rape and incest exceptions at its introduction. The “murder of innocents by statute” was embedded in the new bill, which the national pro-life organizations supported and promoted. It passed the House, but as predicted, it was withdrawn in the Senate after several failed attempts to invoke cloture.
Like other message bills, it had no chance to pass and no expectation that it would truly save lives, but in this case, the equal protection standard was voluntarily breached without a fight. The message was a mess from the beginning—only some preborn children should be protected from pain and death. More on this in a moment.
There is another key feature of message politics that must be understood. The top priority of many message bills is to protect incumbents in the next election, and the bills are often scheduled accordingly. Incumbent legislators vote on a message bill not to try to ensure it becomes law, but to “earn” a 100% approval rating on their pro-life scorecards. They return to their home districts trumpeting their pro-life credentials, often with national endorsements. Repeatedly, our true pro-life statesmen warn us that pro-life leadership provides opportunities for moderate Republicans to appear pro-life to their conservative bases without actually enacting legislation that would effectively restrict abortion and save preborn lives. These leaders and the Republican party get all the benefits and none of the risks of being truly pro-life.
A Flawed Message from Compromised Messengers
The aforementioned strategic meeting in the fall of 2014 included major national pro-life leaders and several well-known U.S. representatives. During this meeting, House leadership announced plans for a vote on H.R. 36 on January 22, 2015, which coincided with the annual March for Life in Washington, DC. If H.R. 36 passed the House, the victory would be announced to the hundreds of thousands at the national march. This fanfare would garner media attention and reignite the base. But this did not happen. Instead, civil war erupted among pro-life advocates.
The normal procedure for introducing a pro-life bill is to construct a “clean” bill and then battle over the language in committee. Amendments and other legislative procedures introduce compromise language, usually authored during closed-door debates between pro-life leaders and caucus members. Arguments of acceptance then emerge: “This is the best we could get,” or “this grants us the greatest good for the greatest number.” This greatest-good approach was first introduced by 19th-century Utilitarian philosopher Jeremy Bentham, who, in seeking a replacement for the 10 Commandments as the universal moral code, also said:
“The greatest happiness of the greatest number is the foundation of morals and legislation.”
For the first time in nearly four decades of pro-life political advocacy, leaders offered a message bill that included rape and incest exceptions as part of their public policy position, as opposed to their subsequent strategic compromise. Both strategies are equally flawed, but this was the first time in my experience that pro-life leadership approved inclusion of exceptions on the front-end. There was no clean bill. As noted earlier, H.R. 36’s author, Representative Trent Franks, had offered an almost identical bill in the 2013 session, but as standard pro-life protocol dictated, it did not include exceptions. Those were negotiated later. He violated this protocol in his 2015 bill by introducing it with the exceptions.
The pro-life movement has long-debated whether exceptions are needed as a matter of strategy in order to pass pro-life legislation. But that debate has always been accompanied by a rationalization: Exceptions are not the desired policy goal, but a strategy of compromise as a means to save some. When challenged, the movement has been quick to declare that exceptions are indeed violations of our movement’s policy, even if political pragmatism is “required to save the 99.” But this was beginning to change, and many in the movement rightly called it out. Efforts were no longer made to cover the hypocrisy of “pro-life” bills that allowed the termination of some innocent preborn children.
This paradigm shift was also emerging in other areas of the movement. A few years earlier, Troy Newman, Executive Director of Operation Rescue, had proposed this strategy to a meeting of national pro-life leaders.  He rejected the biblical approach in favor of “the greatest good for the greatest number.” Criticizing Mother Teresa’s premise that God calls us to be faithful, not successful, he wrote:
“After 40 years of unabated child-killing in America, we can no longer settle for being ‘right’ while the failure of our efforts results in the slaughter of innocent lives. Our mission is not to be morally superior; our mission is to be successful in saving every baby and ending all abortion.”
He advocated acceptance of the supposed political reality that exceptions are necessary for pro-life strategy. In other words, the end justifies the means. It did not matter what God, Mother Teresa, or principled pro-life activists said. He advocated that our guiding star should be pragmatism. Like Jeremy Bentham did in the 19th century, Newman dismissed biblically based moral objections as obstructionist and called for the isolation of dissenting groups. Soon, this practice of rejection was invoked by the National Right to Life Committee. This Utilitarian strategy of “the greatest good for the greatest number” became a poison pill that prolonged suffering and death, rather than a sound prescription for the pro-life movement’s health.
Prior to the January 2015 vote on the pain-capable bill and in my capacity as President of Georgia Right to Life, I had visited and spoken personally with most of our pro-life Georgia delegation. I persuaded them to go to U.S. House Speaker Paul Ryan and demand removal of the exceptions. Thankfully, some did. I had every reason to believe that they would act in accordance with their sworn word and vote against this practice, as they had proven in past battles in Georgia. I was wrong.
Most of these men had been champions of life issues throughout their service as state and federal legislators. We regarded them as the nucleus of a new cadre of principled statesmen who would change the pro-life dynamic at the U.S. Capitol precisely because of their understanding of personhood. Included in this respected group were two pastors, a former Georgia Right to Life chapter leader, and former state Personhood Amendment sponsors in the Georgia legislature. Each of them compromised their deeply held beliefs. To understand why we must first look at the standards set by the Georgia Right to Life (GRTL) PAC.
Through the efforts of the GRTL PAC, Georgia became one of only two states in the nation with no rape and incest exceptions in any of its pro-life laws. State congressional leaders admit that they have been “trained not to allow rape and incest exceptions.”  Georgia is the only state in the nation in which all of its top executive officers (elected on a statewide ballot) are pro-life without exceptions.
Nine of the 10 Republicans in the Georgia congressional delegation had applied for and received the endorsement of the GRTL PAC, which has one of the toughest pro-life endorsement standards in the nation. Before the PAC considers a candidate, he or she must first sign a Personhood Affirmation to assert 100% agreement with the PAC’s positions on all pro-life issues, not just abortion. Each of the nine pro-personhood U.S. House members in our 14-member delegation, with the exception of Representative Tom Price, was elected upon their signing of the Personhood Affirmation, which upholds protection for those conceived in rape and incest:
“As a candidate for public office, I agree to uphold these (Personhood) principles and position…
I affirm my support for a Human Life Amendment to the Georgia Constitution and other actions that would support these principles. This would assure that regardless of race, age, degree of disability, manner of conception . . . the civil rights of the preborn…are violated when we allow…abortion (in the rare case that the mother’s life is indeed endangered by a continuation of the pregnancy, sound medical practice would dictate that every effort is made to save both lives)” [emphasis added].
GRTL PAC made it very clear that the consequence of perjury would result in removal of its PAC endorsement:
“The GRTL PAC will regard a vote for legislation containing language in violation to that described above as a vote in direct opposition to the Affirmation you signed. This action will result in immediate removal of your GRTL PAC endorsement and will be reported in subsequent communications from Georgia Right to Life to the grassroots activists in our state” [Underlined emphasis in the original].
Even though these were all long-time friends and allies, all nine House members lost their GRTL PAC endorsement. The mystery was: What caused these men we trusted and knew so well to suddenly abandon their convictions? The answer was telling. Leaders in the national pro-life movement pressured these Congressmen to violate their consciences. They caused them to stumble, and they fell. Before the vote, in visit after visit, these men shared their stories with me. All had one thing in common: Pro-life leaders told them that if they voted their consciences, they would score them with the pro-aborts—and they did. One Georgia Congressman, with tears in his eyes, shared his Bible verse for that day:
“Fathers shall not be put to death because of their children, nor shall children be put to death because of their fathers…”
His voice choking with emotion, he said he agreed with us, but could not afford to offend these powerful pro-life/pro-family groups. But what about offending Almighty God? Repeatedly, I was told, “Until your own pro-life establishment leaders get their act together, we are going to have to violate our consciences in this area. This is not our fault!” Dr. Martin Luther King, Jr., decried the flawed character of his day when he said:
“The ultimate measure of a man is not where he stands in moments of comfort and convenience, but where he stands at times of challenge and controversy. The true neighbor will risk his position, his prestige, and even his life for the welfare of others.”
Flawed Endorsements Undermine the Cause
One of Georgia’s outstanding pro-life advocates in Congress through 2014 was Representative Paul Broun. For many years, he sponsored the Sanctity of Human Life Act, the landmark bill that embodied the pro-life movement’s stated goal. A Christian medical doctor by profession, Broun was uniquely qualified to represent the personhood of all human beings when he ran for an open U.S. Senate seat in 2014. However, Susan B. Anthony List chose not to endorse him in favor of Georgia Secretary of State Karen Handle, who supported exceptions and had no pro-life track record in her previous elected offices. On the contrary, she had voted as Chairman of the Fulton County Board of Commissioners to fund Planned Parenthood facilities in Georgia. After Handle lost the U.S. Senate race, she joined Susan G. Komen for the Cure as Senior Vice President of Public Policy but resigned amidst the controversy over the organization’s funding of Planned Parenthood.
Susan B. Anthony List also enthusiastically endorsed Representative Renee Ellmers of North Carolina:
"A new women's movement which affirms its original pro-life roots is making its way to the House of Representatives, and Ellmers is one of its brightest new stars."
Ellmers advocated for exceptions based on a preborn child’s manner of conception. This is certainly not an affirmation of the “original pro-life roots” of the women’s movement. Later, Susan B. Anthony List joined other groups who denounced Ellmers as a “pro-life traitor”  when she opposed the 2015 pain-capable bill because it was too stringent in its rape exception. In an ironic twist, Susan B. Anthony List President, Carol Tobias, said this about Ellmers:
“Nothing has the potential to do more damage to pro-life efforts than people who run as pro-life candidates back home in their pro-life districts and then stab the babies in the back when they come to DC and work against pro-life efforts… Thankfully, we’ve been given the chance to send Rep. Ellmers packing.”
Something is deeply wrong when a movement calls evil good and good evil. “We have met the enemy and he is us.”
An Alternate Path: Principled Incrementalism
The experiences of Right to Life of Michigan (RLM) and Georgia Right to Life (GRTL) destroy the fallacy that biblical standards prevent political and legislative success. Georgia has seen widespread no-compromise political and legislative victory. We have accomplished this without surrendering the basic biblical tenets of the sanctity of life. Perhaps this proves the maxim:
“You do not have because you do not ask.”
GRTL successfully created a culture of life in Georgia by upholding a scriptural standard that God has chosen to empower to His glory. We have passed several bills that chip away at abortion-on-demand, without exceptions, including a women’s-right-to-know counseling law, a 24-hour waiting period, parental notification, and preventing abortion coverage in state employee health insurance plans.
We have enacted other laws that affirm the preciousness of every life as well, including an embryo adoption law that facilitates the adoption of embryos as children to whom the state owes “rights and privileges,” rather than as owned property to be transferred by contract. We also passed a law that outlines the procedure for terminating the parental rights of rapists, which protects women from their assailants as they raise their children conceived in rape. We enacted a law to create a cord blood bank, which recognizes the efficacy of cord blood cells in the treatment of disease, rather than embryonic stem cells, which requires the destruction of human beings. The 2017 annual report Defending Life, published by Americans United For Life, listed Georgia as the 8th most protective state in the nation, proving that a principled approach can be achieved without compromise in a large metropolitan culture. The other state which has required a no-exceptions policy—Michigan—is right behind us as the 9th most protective state.
Impetus for Change: The Forming of Personhood Alliance
The clear violation of the personhood of the preborn in the H.R. 36 message bill precipitated another overt break in the pro-life ranks. This break was the impetus for the Personhood arm of the movement to create a new national effort called Personhood Alliance. The new group raised its voice to object to the adulteration of the message, the strategy, and the emerging shift in policy of the major pro-life organizations. In an unprecedented move, LifeSiteNews.com allowed both sides to air their concerns in a very public debate.,  Many alleged this violated the so-called 11thcommandment—speaking ill of fellow pro-lifers. Previously, this spurious decree had been a useful tool for the pro-life establishment to silence principled opposition.
“The exception betrays the whole premise of the sanctity of human life upon which the pro-life movement is built—that ALL human life is precious."
In her public statement, she urged her Ohio representatives to oppose the pain-capable bill until it was corrected. Organizations like Cincinnati Right to Life and Toledo Right to Life led the effort. Like-minded groups all across the country quickly joined them. Together, they pressed their U.S. House members to rigorously object to the national organizations’ 2015 agenda. Dustin Siggins, writing for Crisis Magazine, referred to these organizations as “Beltway life groups:”
“They clearly missed the boat on the 20-week ban (H.R. 36), despite telling everyone to fall into line because they supposedly knew the situation in D.C. They knew what could pass, and could not, and the rest of us ought to listen to them, we were told.
But as is often the case, having D.C. expertise does not always translate to electoral or policy victories, and often compromise is the first step Beltway life groups make, rather than the last. Certainly, the H.R. 36 experience makes it clear that the D.C.-based pro-life organizations can no longer demand grassroots pro-lifers simply send checks and let them do their work.”
Groups like National Right to Life Committee, Susan B. Anthony List, Priests for Life, and Family Research Council were subsequently confronted by their constituents and donors for supporting H.R. 36. Efforts escalated when it became clear that some of these groups punished conscience votes, as noted earlier in this chapter. As U.S. House leadership heard the widespread concerns of the Personhood movement, they realized a train wreck loomed on the horizon. Pro-life public opinion was deeply divided and for the first time, a very vocal alliance of Personhood advocates called for the removal of the destructive language.
Republican leadership attempted to shift the controversy from a widespread movement revolt to a dispute over rape reporting, highlighted by Representative Ellmers. Despite the misdirection, the true nature of the conflagration became apparent. The bill’s author, Representative Trent Franks, explained why the House abandoned the much-trumpeted vote. Speaking the day after the March for Life on National Public Radio’s Morning Edition, Franks acknowledged that the cause of the abandonment was personhood, not the rape-reporting controversy:
“The last time that this country debated or argued among ourselves an issue of this nature and magnitude, where the personhood of a certain group of people was denied in the courts, we shot ourselves to doll rags on the battlefields of the Civil War. At least today, we are talking amicably and trying to work it out.”
However, the two opposing sides were not successful in working things out. It appears that the sanctity of every human life, embodied in personhood, will be the battleground on which future generations of pro-life activists engage. It is a battle worth fighting.
Have the political stars aligned in the heavens? Does it matter? Our job as pro-life advocates and ministry leaders is to uphold a biblical standard and call all mankind to that standard. We are not kingmakers. Winning politically at any cost bankrupts us morally and separates us from God’s favor. In Julius Caesar, Shakespeare concludes his star-struck advice to Brutus by declaring: “The fault, dear Brutus, is not in our stars, but in ourselves.” 
Astrology has never been a trustworthy foundation for life’s actions. Instead, we must act faithfully and put our trust in the Lord and His ways.
“Put not your trust in princes,
in a son of man, in whom there is no salvation.
Blessed is he whose help is the God of Jacob,
whose hope is in the Lord his God.”
“Many seek the face of a ruler, but it is from the Lord that a man gets justice.”
Russian author Alexander Solzhenitsyn shared a profound insight during his famous commencement speech at Harvard University in 1978:
“There are telltale symptoms by which history gives warning to a threatened or perishing society. Such are, for instance, a decline of the arts or a lack of great statesmen.”
If we are to seek justice for the preborn, then our ways must begin and end in alignment with God’s decrees. To do otherwise is to prolong the injustice. God cannot bless that which His commandments forbid. “Changing unjust laws justly”  requires godly prudence in dealing with rulers, not ungodly actions. Rulers are God’s means but not His end. Only Jesus is the Alpha and Omega, the beginning and the end. This we can put our faith in!
[Daniel Becker is the Founder and President of Personhood Alliance. He is also the former President and PAC Director of Georgia Right to Life and a former board member of National Right to Life. He studied at L’Abri Fellowship under the mentorship of Dr. Francis Schaeffer in 1973. A widower, Daniel enjoys investing in the lives of his 26 “grand-blessings.”]
 Proverbs 29:26
 Roe v. Wade. (1973). 410 US 113, No. 70-18.
 Family Policy Alliance. (2017). Statesmen academy. Retrieved from http://familypolicyalliance.com/statesmen-academy/
 This meeting was held at the Georgia Right to Life office in March 2017.
 Ibid., Family Policy Alliance
 Deuteronomy 29:18-19
 Deuteronomy 24:16
 H.R. 36. (2015). Pain-Capable Unborn Child Protection Act. 114th Congress (2014-2015). See text: https://www.congress.gov/bill/114th-congress/house-bill/36
 Obama Threatens to Veto Abortion Bill, http://thehill.com/policy/healthcare/230075-obama-threatens-to-veto-abortion-bill
 H.R. 3803. (2012). District of Columbia Pain-Capable Unborn Child Protection Act. 112th Congress (2011-2012). See text: https://www.congress.gov/bill/112th-congress/house-bill/3803/text
 H.R. 1979. (2013). Pain-Capable Unborn Child Protection Act. 113th Congress (2013-2014). See text: https://www.congress.gov/bill/113th-congress/house-bill/1797
 Burns, J.H. (2005). Happiness and utility: Jeremy Bentham’s equation. Utilitas, 17(1). Retrieved from https://www.utilitarianism.com/jeremy-bentham/greatest-happiness.pdf
 Ibid., H.R. 1979
 Ibid., H.R. 36
 Ibid., Newman & Sullenger, p. 28
 “The end justifies the means” is also a core tenet of Utilitarianism.
 Ibid., Newman & Sullenger, p. 30
 Craddock, Josh (2015), NRLC removes Georgia Right to Life’s affiliation for being too pro-life. Retrieved from http://www.liveaction.org/news/nrlc-removes-georgia-right-to-lifes-affiliation-for-being-too-pro-life/
 Michigan also has no rape and incest exceptions in any of its pro-life laws.
 Stated by Georgia Senate Leader Bill Cowsert in 2013
 Rep. Tom Price (GA 6), currently President Trump’s HHS Secretary, was the only Georgia Republican who did not sign the Personhood Affirmation.
 Georgia Right to Life PAC Personhood Affirmation. See Appendix 1 for full text.
 Mark 9:42 “Whoever causes one of these little ones who believe in me to sin, it would be better for him if a great millstone were hung around his neck and he were thrown into the sea.”
 Representatives Jody Hice in 2015 for voting Present instead of Yea, and Rob Woodall and Paul Broun in 2013 for voting Nay
 Deuteronomy 24:16
 Letter from Birmingham Jail, April 16, 1963
 H.R. 212. (2011). Sanctity of Human Life Act. 112th Congress (2011-2012). See text: https://www.congress.gov/bill/112th-congress/house-bill/212/text
 Particularly, the justification of selective reduction of embryos produced in the IVF process
 Fulton County Board of Commissioners. (2005). Meeting minutes (March 16, 2005). [Page 12, item 2: Planned Parenthood extended family planning contract]. [Page 13 Motion proposed, unanimous vote to award the contract]. Retrieved from http://www.politicalvine.com/karenhandel/Page12BOC-PlannedParenthoodVote.pdf
 Kliff, S., & Aizenman, N. C. (2012). Komen vice president Handle resigns. Retrieved from https://www.washingtonpost.com/blogs/ezra-klein/post/komen-vice-president-karen-handel-resigns/2012/02/07/gIQAYP0WwQ_blog.html?utm_term=.750928033398
 Susan B. Anthony List (2014). SBA List endorses Renee Ellmers for Congress in North Carolina’s 2nd district. Retrieved from http://www.christiannewswire.com/news/1467414385.html
 Ertelt, S. (2016). Pro-life groups defeat ‘pro-life traitor” Renee Ellmers, who almost sabotaged abortion ban. Retrieved from http://www.lifenews.com/2016/06/08/pro-life-groups-defeat-pro-life-traitor-renee-ellmers-who-almost-sabotaged-abortion-ban/
 Kelly, W. (1971). Pogo comic strip.
 Georgia does have an exception in one of its many pro-life laws. Five State Senators insisted that an exception for fetal anomaly be added to the Georgia Pain-Capable Bill in closing hours of the 2013 legislative session. The GRTL PAC withdrew its endorsement of the bill and publicly opposed the five senators who compromised the bill. As of the time of writing, four of those senators no longer serve as lawmakers.
 James 4:2
 Americans United for Life. (2017). Defending life report 2017. Retrieved from http://www.aul.org/wp-content/uploads/2017/03/DefendingLife2017.pdf
 Kiessling, R. (2016). You want us to compromise our pro-life values MORE?!! Retrieved from http://www.grtl.org/?q=you-want-compromise-pro-life-values-more
 Jones, G. G. (2015). Four reasons why I can’t support the 20-week abortion ban and you shouldn’t either. Retrieved from https://www.lifesitenews.com/opinion/four-reasons-why-i-cant-support-the-20-week-abortion-ban-and-you-shouldnt-e
 Nance, P. (2015). Why the pro-life movement should unite behind the pain-capable 20-week abortion ban. Retrieved from https://www.lifesitenews.com/opinion/why-the-pro-life-movement-should-unite-behind-the-pain-capable-20-week-abor
 Previously, in 2013, Cleveland Right to Life and GRTL had their 40-year affiliation with NRLC revoked.
 Ibid., Jones
 Siggins, D. (2015). How to strengthen Republican opposition to abortion. Retrieved from http://www.crisismagazine.com/2015/getting-republicans-take-abortion-seriously
 Personhood Alliance. (2015). Congress to authorize abortion in 'pro-life' bill. Retrieved from https://www.personhood.org/index.php/press/ press-releases/congress-to-authorize-abortion-in-pro-life-bill
 Summers, J. (2015, January 23). House approves a measure that would bar federal funding for abortion. Morning Edition. [Transcript of radio interview with Rep. Trent Franks. Host, David Greene]. Retrieved from http://www.npr.org/2015/01/23/379282671/house-approves-measure-that-would-bar-federal-funding-for-abortions
 William Shakespeare, Julius Caesar (1599)
 Psalm 146:3-5
 Proverbs 29:26
 Harte, C. (2005). Changing unjust laws justly: Pro-life solidarity with “the last and the least.” Chicago: Catholic University of America Press.
 Romans 13
 Revelation 22:13