The conceptual—and legal—division between a woman and a fetus is most recently rooted in the Supreme Court's 1973 Roe v. Wade decision, which established the trimester framework designed to balance a woman's right to privacy with the state's interest in protecting potential life. Prior to Roe, a woman and her fetus were legally viewed as having identical interests because of their biological tie. The trimester framework, however, established a precedent for viewing the maternal-fetal relationship as an adversarial one, where a woman and her fetus have conflicting interests. Indeed, as states demonstrate their willingness to protect fetal health—via restrictions on access to abortion—the fetus is increasingly being viewed as a separate entity that is entitled to protection and recognition as a person. The questions of when and under what conditions a fetus is a person have policy implications beyond the scope of the abortion debate.