"Roe’s legal judgment about the meaning of the term “person” was far from inevitable. A pre-Roe federal district court decision determined that the rationale of Griswold v. Connecticut did not extend to abortion and distinguished between contraception, which prevents the creation of human life, and abortion, which destroys existing human life. Rejecting the privacy argument, the three-judge panel ruled: [T]he legal conclusions in Griswold as to the rights of individuals to determine without governmental interference whether or not to enter into the process of procreation cannot be extended to cover those situations wherein, voluntarily or involuntarily, the preliminaries have ended, and a new life has begun. Once human life has commenced, the constitutional protections found in the Fifth and Fourteenth Amendments impose upon the state the duty of safeguarding it."