"For example, Paulsen [1989, pp. 49, 76 –77] considers legalized abortion to be worse than slavery (since it involves death) and the Holocaust (since the 34 million post-Roe abortions are numerically greater than the six million Jews killed in Europe). Despite these claims, the Supreme Court has ruled that women have a fundamental constitutional right of privacy to abort an early-term fetus and that the state cannot unduly burden this right."