"Were fetuses to be given the full legal protection accorded to born persons, the resemblance between forced pregnancy and slavery might eventually become more apparent. In recent decades, medical science has found that a broad range of activities by pregnant women can have a negative effect of the fetus, “including failing to eat properly, using prescription, nonprescription and illegal drugs, smoking, drinking alcohol, exposing herself to infectious disease or to workplace hazards, engaging in immoderate exercise or sexual intercourse, residing at high altitudes for prolonged periods, or using a general anesthetic or drugs to induce rapid labor during delivery.” Note, “The Creation of Fetal Rights: conflicts with Women’s Constitutional Rights to Liberty, Privacy, and equal Protection, 95 Yale L..H. 599, 606-07 (1986) (footnotes omitted). There are two ways of using this information: by communicating it to women and trusting them to use it appropriately, or by regulating pregnant women’s behavior directly. The former approach only makes sense if pregnant women can be presumed to care about the welfare of their fetuses, and this presumption will be implausible if one and a half million women a year (that is, between quarter and a third of pregnant women) are pregnant against their wills. See Tierze, Forrest & Henshaw, supra note 130, at 475-76. The latter approach has already, in some cases,been carried to its logical conclusion of imprisoning the woman for the duration of her pregnancy. See e.g., 1989 Minn. Sess. Law Serv. P 290, Part. 5 (West) (statute authorizing involuntary civil commitment of women who abuse drugs during pregnancy). Recognition of fetal personhood might entail internment of pregnant women on a much larger scale."