"In one passage the Court spoke of the unborn before viability as "a theory of life," as though there were competing views as to whether life in fact existed before viability. The implication could also be found that there was no reality there in the womb but merely theories about what was there. The Court seemed to be uncertain itself and to take the position that if it were unsure, nobody else could be sure. In another passage the Court spoke of life in the womb up to birth as "potential life." This description was accurate if it meant there was existing life with a great deal of development yet to come, as one might say a 5-year-old is "potential life" meaning that he or she is only potentially what he or she will be at twenty-five. The Court's description was inaccurate if the Court meant to suggest that what was in the womb was pure potentiality, a zero that could not be protected by law. To judge from the weight the Court gave the being in the womb-found to be protectable in any degree only in the last two months of pregnancy-the Court itself must have viewed the unborn as pure potentiality or a mere theory before viability. The Court's opinion appeared to rest on the assumption that the biological reality could be subordinated or ignored by the sovereign speaking through the Court."