"Justice Blackmun thought it significant that some states in the mid-nineteenth century did not prosecute women who procured abortion, and found this policy incompatible with prenatal life being included within the scope of the Fourteenth Amendment. As already mentioned, however, this immunity likely stemmed from the notion that women were victims of abortion rather than perpetrators. On a practical level, the most likely witness against a criminal abortionist was a woman upon whom an abortion had been performed. Therefore, the legislature may have granted immunity to women in the interest of convicting criminal abortionists. Lending credence to this position is that nearly all states that did impose criminal penalties on abortive women offered immunity to those women who testified against an accused abortion provider. Despite all these considerations, at least seventeen states imposed criminal sanctions upon women who underwent surgical or chemical abortion."