"In Rich v. Foye, a Connecticut state court briefly mentioned that “[r]ecognizing a claim for wrongful life can also be problematic because any theoretical fetal rights either to come to term or not are subject to the mother’s legal rights pertaining to control of her pregnancy.” Additionally, the Oregon Supreme Court briefly noted the conflict between the child’s claim and the parent’s right to terminate the pregnancy: There can be no doubt that recognizing that a child in T’s position has an interest in not being born is distinct from, and potentially at odds with, the parents’ interests [in making informed reproductive choices] recognized above . . . Thus, recognizing a child’s independent legal interest in being conceived and born (or not being conceived and born) would create potential tension with the parents’ legal interest in deciding whether or not to conceive and bear that child. Therefore, there is no duty to a fetus in the first trimester. Without a duty there can be no proximate cause and no damages, thus no liability."