If the Roe draft becomes case law, the next step in the pro life playbook is pretty obvious. It would be to obtain a declaration from the U.S. Supreme Court that a fetus is a "person" for some constitutional purpose and therefore has a constitutionally protected right to life. At a stroke of "judicial legislation" abortion would be outlawed throughout the United States. This is unlikely but far from impossible. The Supreme Court has defined "person" repeatedly throughout the nation's history covering claims from slaves to corporations. Such a decision would not be subject to appeal or repeal short of an unlikely constitutional amendment. Who can say that this Court would never do such a thing?