"Justice Blackmun’s coherence arguments are severely undercut by his naïve assumption that “personhood” means no abortions at all. He noted some features of the law of homicide which would be anomalies if the unborn were truly persons. It is certainly the case that abortion has been distinguished as a particular form of homicide, punishable approximately as manslaughter, with the important caveat that women procuring abortions were rarely prosecuted at all. Abortion has not been a class of applications of murder prohibitions. What does all this show? Not nearly what the Roe Court thought it showed. Justice Blackmun examined the case for “fetal personhood” under the Fourteenth Amendment’s Due Process Clause. It says. “[N]or shall any state deprive any person of life, liberty, or property, without due process of law; !* * *.” He seems to have thought that a successful argument for fetal personhood would constitutionally prohibit all abortions. He said that if fetal personhood could be established, the case for abortion liberty “of course, collapses, for the fetus’s right to life is then guaranteed specifically by the Amendment.”"