"Bailey’s definition of involuntary servitude as “that control by which the personal service of one man is disposed of or coerced for another’s benefit” encompasses the burden imposed on women by laws against abortion, since the “natural operation” of a statute prohibiting abortion is to make it a crime for a woman to refuse to render service to a fetus. Even had the decision been differently worded, any decision in Bailey’s favor would probably protect the woman who seeks to abort, since the servitude to which Bailey was subjected was considerably less-less taxing, less intrusive, and less total in its probable impact on the course of his whole life-than that which forced pregnancy imposes on her. Bailey also provides an answer to those who would dispute that the servitude is involuntary. As I noted earlier, some opponents to abortion think that women should be considered to assume the risk of pregnancy when they consent to have sex. This argument is far-fetched, but even if women did deliberately assume such a risk, Bailey holds that the right to personal liberty guaranteed by the thirteenth amendment is inalienable. The full intent of the constitutional provision could be defeated with obvious facility if, through the guise of contracts under which advances had been made, debtors could be held to compulsory service. It is the compulsion of the service that the statute which enforces the amendment inhibits, for when that occurs the condition of servitude is created, which would not be less involuntary because of the original agreement to work out the indebtedness."