Catholics, Contraception, and Conscience

Now that we've had — and are still having — the brouhaha over whether quasi-religious institutions — Catholic-run schools, hospitals, universities, charities — ought to be exempt from the federal mandate to provide employees with health insurance that covers contraception without copays or deductibles, I'd like to look at what the brouhaha was all about in the first place.

Particularly, why do Catholic bishops oppose contraception? I've seen little in the standard news coverage and opinion writing that tells that story at its fullest.

Unfortunately, I myself am no authority on the matter. I can offer but a partial answer to readers, so check me on all I am about to write.

As a person who came into the Catholic Church in middle life from a Protestant/secular background, I was not immediately affected in 1968 when Pope Paul VI issued his famous encyclical Humanae Vitae (literally, "On Human Life"), whose alternate title is "On the Regulation of Birth." Humanae Vitae (pronounced Who-mah'-nay Vee'-tay) reaffirmed the Catholic Church's traditional view of marriage and conjugal relations and condemned (not for the first time!) artificial methods of birth control. Catholics were not permitted to use the then-new oral birth-control pill. Nor were condoms allowed — which reaffirmed the existing teaching on those devices.

According to Wikipedia's discussion of Pope Paul VI's various encyclicals:

Paul VI teaches in the first sentence of Humanae Vitae that the transmission of human life is a most serious role in which married people collaborate freely and responsibly with God the Creator. This divine partnership [between a married couple and God] ... does not allow for arbitrary human decisions, which may limit divine providence.

Later on, the same Wikipedia discussion adds:

Pope Paul was concerned but not surprised by the negative reaction [to Humanae Vitae] in Western Europe and the United States. He fully anticipated this reaction to be a temporary one: "Don't be afraid," he reportedly told [Canadian Cardinal Édouard Gagnon] on the eve of the encyclical, "in twenty years time they'll call me a prophet."

It has, quite obviously, taken more than twenty years for that to happen. We're still up in arms over contraception and its concomitants as they affect women's rights and women's health insurance coverage.

The Catholic Church's Reverence for Conception

What, from a Catholic perspective, underlies this dispute? It needs to be noted, first of all, how very, very highly the Catholic Church reverences conception. Conception is more than just the uniting of a man's sperm with a woman's egg, even more than the start of a human life. In addition to those, it is an occasion for calling to mind and honoring the entire gamut of joys, interpersonal relationships, and lifetime commitments that the idea of biological conception is meant to activate within us — including the consecrated relationship of a loving couple to God.

For the married couple, conception (once the pregnancy test turns out positive and an embryo is known to be present in the womb) is meant to be an occasion for great joy. In anticipation of the possibility of conception and pregnancy, each conjugal union is meant to be an act of physical pleasure and spiritual affirmation. Once a child is on its way, the couple is meant to reaffirm in attitude, thought, and deed its commitment to bringing him or her into the world and raising him or her to adulthood with mutual dedication and love.

The demand on the woman who must carry the pregnancy to term; go through the prolonged gestation period; then endure labor and childbirth; and then provide nutrition and nurture to the newborn child is a great one. The man has less to do early on, but he must faithfully persevere in supporting the family unit and being true to his marriage vows. Dad's contribution to the child-rearing process will increase as time goes on, and the youngster becomes less dependent on Mom.

That's the ideal. I think the insistence of the Church on the sacredness of human conception is meant to bring the whole of that ideal, including but not limited to biological conception per se, into the sharpest possible focus.

Put bluntly, then, sexual gratification all by itself is never front-and-center. Sex severed from reverence for conception is, the Church says, "intrinsically disordered."

We need to keep in mind that this reverence for conception does not limit sex by married couples to couples who are capable of conceiving a child. Married couples in which the woman is past the age of menopause can legitimately enjoy sex, as can married couples in which a partner is infertile. The same is true when a mother, breastfeeding her baby and not ovulating each month, cannot get pregnant.

The Catholic Church Says All Acts of Conjugal Love Must Be "Open to Conception"

The Catholic reverence for conception is why it is said by Catholic authorities that every sex act engaged in by a married couple must be "open to conception." That phrase echoes "open to the transmission of life" in paragraph 11 of this translation of the Latin in which Paul VI wrote Humanae Vitae. The Catechism of the Catholic Church, for its part, uses the phrase "openness to fertility" to head sections 1652-54.

How exactly is this phrase "openness to conception/fertility/transmission of life" to be construed?

In Humanae Vitae, Paul VI expressly insists on "safeguarding both ... essential aspects [of conjugal love], the unitive and the procreative." These two aspects of conjugal love, unitive and procreative, are said by the pope to be crucially bound up with one another. The pope writes:

11. These acts, by which husband and wife are united in chaste intimacy, and by means of which human life is transmitted, are, as the [Second Vatican] Council recalled, "noble and worthy," and they do not cease to be lawful if, for causes independent of the will of husband and wife, they are foreseen to be infecund, since they always remain ordained towards expressing and consolidating their union. In fact, as experience bears witness, not every conjugal act is followed by a new life. God has wisely disposed natural laws and rhythms of fecundity which, of themselves, cause a separation in the succession of births. Nonetheless the Church, calling men [and women] back to the observance of the norms of the natural law, as interpreted by their constant doctrine, teaches that each and every marriage act ... must remain open to the transmission of life.

12. That teaching, often set forth by the magisterium [the teaching authority of the Church], is founded upon the inseparable connection, willed by God and unable to be broken by man on his own initiative, between the two meanings of the conjugal act: the unitive meaning and the procreative meaning. Indeed, by its intimate structure, the conjugal act, while most closely uniting husband and wife, capacitates them for the generation of new lives, according to laws inscribed in the very being of man and of woman. By safeguarding both these essential aspects, the unitive and the procreative, the conjugal act preserves in its fullness the sense of true mutual love and its ordination towards man's most high calling to parenthood. We believe that the men [and women] of our day are particularly capable of seeing the deeply reasonable and human character of this fundamental principle.

It's fair to assume that "openness to conception/fertility/transmission of life" is, in the papal view, the procreative meaning of sex. Put simply, it can never be legitimately severed from the unitive aspect by which sex binds two spouses closer together, thereby "expressing and consolidating their union." If the two inseparable aspects of sex are in fact distanced from one another by means of artificial birth control, the married couple fails (per paragraph 10 of Humanae Vitae) to "conform their activity to the creative intention of God, expressed in the very nature of marriage and of its acts, and manifested by the constant teaching of the Church."

In paragraph 13 of Humanae Vitae, Pope Paul VI adds to that:

To use this divine gift [of conjugal love] destroying, even if only partially, its meaning and its purpose is to contradict the nature both of man and of woman and of their most intimate relationship, and therefore it is to contradict also the plan of God and His will.

So conjugal acts which are "foreseen to be infecund" do not destroy the "meaning and purpose" of the conjugal acts themselves, "since they always remain ordained towards expressing and consolidating" the union of the married pair. That's why natural family planning — the "rhythm method" — is legitimate. But, in the view of Paul VI, if the infecundity is artificially produced, the "meaning and purpose" of the conjugal acts is illicitly corrupted.

The Ongoing Dispute within the Church over Contraception

"Contraception," says Fr. Richard P. McBrien in his thick compendium of the Catholic faith, Catholicism, is what Church teaching specifically forbids — not "birth control" per se. Natural family planning (formerly called "the rhythm method") is allowed, after all, and clearly it counts as a method of "birth control." "Contraception" per se, though, is "the intentional placing of a material obstacle to the conception of a child: e.g., a contraceptive pill, an intrauterine device, contraceptive foam, a condom" (p. 982), and it is what is not allowed.

I gather that a pharmacological method such as the well-known oral birth-control pill counts as "a material obstacle" in this respect, and it is officially deemed as objectionable as a condom is.

McBrien talks (pp. 982-992) about the strict official teaching of the Church concerning contraception, and also about "the other side" in this debate, which

... argues that contraception may not only be legitimate under certain circumstances but even mandatory. This side speaks in terms of "responsible parenthood."

The "other side" consists of faithful Catholics who dispute the position taken by Paul VI in Humanae Vitae. Non-Catholics reading this should accordingly realize that there does exist within the Church an ongoing internal dispute about contraception. However, the strict official teaching of the Church insists that contraception, as McBrien has specifically defined it, is forbidden to Catholics.

McBrien alludes to three main areas of dispute. He says the two sides differ in their respective understandings of:

• natural law
• the binding force of official Church teachings
• the development of Church doctrine

Non-Catholics who are reading this simply to comprehend the current controversy over federally mandated contraception coverage need not examine the two sides' respective cases in depth. They represent an "internal family dispute" among Catholics, after all. The "official" position of the Church is what counts, I'd say, in the mandated contraception coverage debate. Why? Because the bishops' objection to such coverage is that it forces them to violate their Church's official position — and thus it violates the "conscience" of the Catholic Church.

The Catholic Church's Heavy Reliance on "Natural Law"

Still, some of the basic ideas fueling the internal dispute are important for anyone trying to see what underlies the current argument over federally mandated contraception coverage. First, and most importantly, the teachings and doctrinal history of the Catholic Church place heavy emphasis on "natural law." According to Wikipedia:

The Roman Catholic Church holds the view of natural law set forth by Thomas Aquinas particularly in his Summa Theologica ... 

The Summa Theologica was written by Thomas Aquinas in 1265–1274. It established a theological/philosophical basis by which most imaginable questions about God-given human nature could be answered. The Summa Theologica, says Wikipedia, "presents the reasoning for almost all points of Christian theology in the West."

According to Aquinas's formulation of natural law, says Wikipedia:

Humans are capable of discerning the difference between good and evil because they have a conscience. There are many manifestations of the good that we can pursue. Some, like procreation, are common to other animals, while others, like the pursuit of truth, are inclinations peculiar to the capacities of human beings. 

"Common to other animals"? How is this commonality important? Well, notice that in reasoning about natural law, we can understand our human capacity for conjugal love, at least in part, by examining what animals use sex for: reproduction. Accordingly, if we humans use artificial means of contraception to sever sex from reproduction, then the sex act can be called intrinsically disordered: against God-given human nature, as ordered by the principles of natural law.

To the best of my understanding, this appeal to natural law is a peculiarly Catholic way of discerning right from wrong. I am not aware that any other religious denomination considers its faithful to be bound by Aquinas-style natural-law reasoning in this way. I do not mean that all other faiths endorse artificial contraception, but if they do not, they may have other ways of reasoning to that conclusion.

Lay Catholics Respond to the Mandated Contraception Controversy

In her letter to the editor of The Washington Post (Feb. 5, 2012) Falls Church, Virginia, resident Mary Clare Murray states the official Catholic view of contraception in this elegant way:

In her Feb. 12 column, “A new front in the culture wars,” Lisa Miller said that “birth control is noncontroversially good for families and children.” Since this conversation arises because of the Catholic Church’s reaction to current events, this might be a good time to explain what the church teaches regarding birth control. 

It is not just that using birth control closes a man and woman off from sharing in God’s creation of life, it is also that using birth control closes the couple off from a full expression of love, which is total self-giving and the commitment to stay together, regardless of what life brings. 

Sexual intimacy is not meant to be entertainment. It is meant as something beautiful that will bind two people in a permanent union of selflessness, which is really what is “good for families and children.” The misuse of this is not “noncontroversially good” but rather a sound explanation for the devastating divorce rate, sexually transmitted diseases, depression and other illnesses; the couple’s bodies are sharing a commitment, but their minds aren’t. That’s not good for anybody.

I'd say this expresses quite beautifully the official teaching of the Catholic Church about marriage, sexual union, birth control, pregnancy, and the mutual sharing of long-term family responsibilities. The basic point is that sex should open us up, not close us off. A "permanent union of selflessness" on the part of the married couple is a sine qua non of sex ... but so too is the sex act's fundamental "openness to conception."

I would add that the couple's underlying attitude toward conception is a litmus test for the quality of the marital union, or so the Catholic Church would say.

But not all conscientious Catholics agree. This published response to Ms. Murray's letter came from Angela Corigliano Murphy of Bowie, Maryland:

Ms. Murray stated that contraception, which is a temporary inducement of infertility, “closes the couple off from a full expression of love, which is total self-giving and the commitment to stay together regardless of what life brings.” Let’s carry this idea through to its logical conclusion. What happens when infertility is biological and permanent, such as when the wife goes through menopause? Are the husband and wife now closed off from a full expression of love? When I went through menopause, some 20-plus years ago, should my husband and I have stopped expressing our love for each other physically because we could no longer have children? I find that notion highly risible.

No, sexual intimacy is not entertainment, but neither does it cease to be “a full expression of love” when it cannot result in procreation, whether temporarily or permanently. 

I myself would argue that Ms. Murphy is somewhat mistaken in her logic, in that the official position of the Church carefully distinguishes between natural and artificial inducements of infertility. Menopause is natural, and post-menopause sex between husband and wife indeed serves the remaining — i.e., unitive — purpose of conjugal relations. For natural reasons, "a full expression of love" after menopause cannot produce a baby. Yet it is fully in accord with natural law for husbands and wives of post-fertility age to continue to relish sex.

It's not just about the physical possibility of conception, then. It's about all the things associated with conception, when conception is possible and is taken in its broadest, most abstract sense — and it's especially about what those things "truly mean."

The Church endorses natural family planning methods (the rhythm method, which amounts to abstaining from intercourse during certain parts of the menstrual cycle) since they take advantage of what Humanae Vitae calls "a faculty provided by nature." As with post-menopause sex, this is a case in which conjugal sex is legitimate, even if apart from the possibility of purely biological conception.

I have to conclude, then, that the Church wants Catholics to reverence conception in the abstract — even when "faculties provided by nature" happen to prevent the biological union of sperm with egg.

So, when the bishops balk at covering contraception in health insurance paid for by Catholic-run institutions, they're standing fast for a time-honored worldview that Pope Paul VI in 1968 thought would reassert itself "in twenty years time."

The Official Catholic Teaching vs. Pro-Contraception Belief

It's a worldview that is quite clearly at odds with the one that predominates in our culture today. In today's dominant worldview, women have the right to contraception, to free coverage thereof in their health insurance plans, and even to discretionary abortions when needed and as desired.

There are excellent arguments to be advanced in favor of this dominant worldview. One is the who's-fooling-whom argument: the vast majority of Catholic women use artificial contraception at some point in their lives. I've read that the figure is fully 98 percent, but this article in The Washington Post says it's lower.

I dug into the matter and found that, according to "Countering Conventional Wisdom: 
New Evidence on Religion and Contraceptive Use," an April 2011 report by Rachel K. Jones and Joerg Dreweke for the Guttmacher Institute, 68 percent of Catholic women "at risk of unintended pregnancy" use "highly effective methods" of birth control — sterilization, the pill or other hormonal pharmaceuticals, or IUDs. Fifteen percent rely on condoms. Two percent use natural family planning/the rhythm method. Four percent use other means of birth control. And eleven percent use no method at all.

That data can be found in the table "Supplementary table to Figure 3. Current contraceptive use among women at risk of unintended pregnancy, by religious affiliation, 2006–2008 NSFG" at the very end of the report, and can also be seen as the second table here. ("NSFG" refers to the National Survey of Family Growth, conducted by the Centers for Disease Control and Prevention.) The controversial 98 percent figure comes from the first of the two tables on that same page, and is shown as derived from "Unpublished tabulations of the 2006-2008 National Survey of Family Growth." It refers to surveys of all women who have ever had sex, not just women who are "at risk of unintended pregnancy."

However the numbers are to be parsed, one argument in favor of mandated contraceptive coverage is that large numbers of Catholic women use contraceptives. Contraception-tolerant arguments are also heard, within the Church itself, from a number of its opinion leaders both ordained and lay. Father Richard P. McBrien notes in Catholicism that a "Papal Commission for the Study of Population, the Family, and Birth" produced, in 1966, just two years prior to Humanae Vitae, two reports: a majority report favoring a reconsidered view of contraception and a minority report insisting on the traditional view that artificial contraception is intrinsically disordered.

When Pope Paul VI promulgated Humanae Vitae in 1968, he sided with the minority, not the majority.

The promulgation of Humanae Vitae triggered a hue and cry from liberal Catholic opinion leaders who had imagined that the pontiff's much-anticipated encyclical was going to affirm the perspective of the commission's majority, not that of the minority. Per McBrien:

According to the majority opinion, the argument [of the minority] in favor of the traditional teaching based on [the Church's longstanding] authority fails to recognize the evolutionary character of that teaching.

The Catholic Church has traditionally maintained that its hierarchy possesses a magisterium — a teaching authority — that illuminates what Catholics believe. In addition to dogma, opposition to which constitutes heresy, there is a much vaster body of official doctrine which the magisterium urges on Catholics. The teaching of Humanae Vitae is a matter of such doctrinal teaching, and must be taken very seriously by Catholics — yet it is not to be considered the infallible teaching of the pope. Catholics may dissent from it in good conscience.

The dissenting faction against Humanae Vitae in 1968 asserted that Paul VI had failed to recognize that Catholic doctrine has evolved significantly in the past and must be allowed to evolve concerning contraception in the present. For example, in the past, usury — the lending of money at interest — had been disallowed. Times changed, and modern banking emerged. Lending of money at interest became the norm in secular society ... and the Church changed its doctrine to permit it.

In the modern world, the liberals' thinking went in 1968, the traditional doctrine against contraception needed to change. Why? In part, because (as the liberals writing the 1966 majority report had urged) a principle of totality dictates that (per McBrien):

... the conjugal act itself must be viewed not as an isolated reality but in the larger context of human love, family life, education, etc. ... Sexuality is not ordered only to procreation. Sacred Scripture says not only "Be fruitful and multiply" (Genesis 1:28) but also "they become one flesh" (2:24), portraying the partner as another helpful self (2:18). [The majority report stated that] "In some cases intercourse can be required as a manifestation of self-giving love, directed to the good of the other person or of the community, while at the same time a new life cannot be received. This is neither egocentricity nor hedonism but a legitimate communication of persons through gestures proper to being composed of body and soul with sexual powers."

McBrien says that the liberals' posited principle of totality was flatly "declared erroneous" by Paul VI in Humanae Vitae.

Looking back at Angela Corigliano Murphy's objection to the traditional view of contraception expressed by Mary Clare Murray in the Washington Post opinion section, I'd say it implicitly endorses the principle of totality. Crucially, to Murphy, sexual intimacy does not "cease to be 'a full expression of love' [even] when it cannot result in procreation." Her letter to the editor would seem to show that the liberals' posited principle of totality in 1968 is still at work in Catholic lives and minds, even today.

Yet, the ghost of Paul VI would argue, the liberal position actually fails in its mission to ensure complete "totality." If a married couple is fertile, then, by our very nature as human beings, conjugal intimacy and openness to conception must go together, Paul's ghost would say. Breaking that natural link by artificially suppressing the procreative aspect of sex goes against God's plan and imperils society's good order.

A Woman's Right to Contraceptive Coverage?

I don't know whether theological-moral disputes of this sort make any sense whatever to non-Catholics, especially secular ones who do not profess faith in a religion. Let me try to put the issue under a slightly different microscope, instead. I think a fundamental question here is whether women have a right to sex without costs and consequences.

Costs: the monetary outlays just for using the oral contraceptive pill can be up to $600 a month. But the dollar costs of having a baby and raising it to adulthood are vastly more huge.

Consequences: specifically, pregnancy, childbirth, and, barring adoption, motherhood. The sacrifices and sheer difficulties inherent in raising a child for X number of years, perhaps with no father around to share the burden. Also, possibly having to give up a career to become a full-time mom, meaning taking big-time hits to life plans and economic prospects.

Is there, then, a right justly claimed by American women that they must not be forced to bear the costs and consequences of having sex? At least, not if human ingenuity and artifice can have anything to say about it.

This question may be the linchpin of this whole debate. If you think women do have such a right, I can pretty well predict how you would answer all the other questions surrounding the issue. For example, if you think such a right exists, you would typically say that women's health insurance plans must, all of them, cover birth control with no extra premiums, deductibles, or copays.

On the other hand, if you deny that such a right exists, you are likely in sympathy with the pronouncements of the bishops on the matter — even if you yourself are not a Catholic.

The Catholic Church denies that there is such a right, because the Church has always taught that there can't be such a right. Catholic doctrine says flatly that all conjugal acts (a) must be between married partners of the opposite sex and (b) must be open to the transmission of life. The idea that sex can and ought to be freely engaged in while blocking its expectable natural consequences is "gravely disordered." End of discussion.

When the Obama administration announced its original policy making free contraceptives universally mandatory in women's health insurance, it included a carve-out to the effect that churches per se were exempt. The carve-out was a narrow one, since it applied strictly only to religious congregations and their immediate employees. Then, Catholic bishops and others howled in protest. What about, they asked, our various hospitals/schools/charities that aren't included in the exception?

The administration was forced to broaden the carve-out to include those semi-secular institutions.

When that happened, some liberal Catholics felt relieved. The United States Conference of Catholic Bishops, though, did not. On the other side of this issue, some pro-choice groups called the modified rule a sell-out, because women employees of Catholic institutions who are not themselves Catholic or those who use contraception despite the Church's teachings would now be left without coverage — an unacceptable situation if you believe women have the right to have sexual intercourse freely, without putting themselves in line for undesired consequences and costs.

Widening the Scope of the Discussion

One can cast the discussion narrowly as a contrast between two competing values:

1. A woman's proclaimed right to sex without consequences, and therefore to contraceptives at no cost.
2. The Church's proclaimed right to act within the dictates of its official conscience.

Put that way, it's hard for me personally to decide which value ought to trump the other.

Arguments from within the Church and outside it to the effect that Church teachings on contraception ought to be updated, since they've "evolved," don't really help me settle the matter. Whether or not it's so, the fact remains that right now the Catholic Church bans contraception as a matter of moral and theological principle. Until that changes, I don't see how it's right for the government's agenda to trample over the Church's religious teachings.

Then again, so many Catholics do in fact use artificial contraception that it's hard to think of "the Church" as being united on this issue. Meanwhile, two generations of American women of whatever religious background have been raised to believe that there's nothing whatsoever wrong with using contraception, and it cannot be denied that they feel a great deal more free than their grandmothers did, simply because they understand that sex can, if they choose, be without consequences.

But what's missing in what I have said so far is, I think, the question of the consequences of widely available contraception as they pertain to the larger society.

You might think that oral contraceptives' introduction in 1960 would have led to a state of affairs in which there were fewer unwanted pregnancies and (post-Roe v. Wade in 1973, which legalized abortion) almost no need for abortions — that, in the famous words of President Clinton, abortions would be "safe, legal, and rare."

Abortions are safe today, and they are legal, but they're not rare. According to "United States abortion rates, 1960-2008," there were over 1.2 million abortions in the United States in 2008. Most of them were, I assume, due not to medical necessity but to the fact that prospective mothers declined, however regretfully, to carry their fetuses to term. That abortion rate, admittedly, was somewhat down from over 1.6 million in 1990.

Prior to Roe v. Wade, the Supreme Court decision which legalized abortion in 1973, abortions in the United States rose from a paltry 292 in 1960, the year the Pill was introduced, to 586,760 in 1972, the last pre-Roe year.

This useful graph represents the statistics:

Ratio = the number of abortions per live births; % = abortions as percentage of total pregnancies (live births + abortions).

Then there's the question of babies born out of wedlock, mothers who aren't married, and single-parent families. Columnist George F. Will writes recently in The Washington Post that

... now more than 50 percent of all babies born to women under age 30 are born to unmarried mothers. ... In 1965, [the late Senator] Daniel Patrick Moynihan, then in President Lyndon Johnson’s administration, published his report on the black family’s “crisis,” which was that 24 percent of black children were then born to unmarried women. Today, 73 percent are. Forty-one percent of all children are now born to unmarried women.

How could the wide availability of birth control have led to more, not fewer, post-Roe abortions and more, not fewer, fatherless children today?

If the Catholic bishops are right, the crux of the problem is that contraceptives unhinge sex from its procreative aspect. And if Paul VI was right in Humanae Vitae, that undesirable result was apt to be accompanied by another one: the unhinging of sex from its unitive aspect as well. The procreative and unitive aspects of conjugal sex are intrinsically inseparable, Paul VI wrote. Sex both produces new life and unifies prospective parents in a deeper bond of mutual commitment.

Sever sex from its procreative aspect and — given that widely available contraception so often fails to prevent unwanted pregnancies — you get abortions numbering in seven figures nationally. Sever sex from its unitive aspect and you get an epidemic of single motherhood.

These are, however, social pathologies and have no clear remedy in the realm of public policy, George Will writes. For example:

The entitlement state can be reformed by various known — if currently politically impossible — policy choices. But no one really knows the causes of family disintegration, so it is unclear whether those causes can be combated by government measures.

The Pill is not a direct cause of (paradoxically) high abortion rates, nor is it a direct cause of family disintegration. No one is saying that it is. Yet it is clear (to me at least) that contraception's wide availability has contributed to those social pathologies — while in its more positive aspect it has contributed to the justly applauded liberation of women in our society.

Also clear to me is that we need to strike the proper balance between legitimate public policy concerns — e.g., women's access to contraception under their health plans — and legitimate expressions of religious conscience such as the Church's principled refusal to be accomplices in same. Only out of the careful balance between these competing world views can come the next evolutionary step in the culture wars.