Laws against partial-birth abortion had strong bipartisan support. They were attempts to mark an outer limit to the abortion right of Roe . If unborn children could not be protected within the womb, could they at least be protected when partway out? That would be illogical, said Judge Barry. But if the location of fetal death does not matter, then it could hardly matter if the child was all the way outside the womb. Laws against infanticide, too, must be dismissed as irrational line-drawing. The intellectual architect of the Born-Alive Infants Protection Act, Hadley Arkes, mentions Judge Barry’s decision in his book on the origin of that law, explaining that it was in part designed to head off the dangerous implications of such rulings.