 Feminists also criticize the US Supreme Court’s reasoning in support of the state interest in protecting potential life. One concern is the scope of the supposed interest, such as whether it extends to the sale or distribution of contraceptive devices that prevent implantation after fertilization, or that even are claimed to do so in rare cases. Another concern is how any interest in protecting fetal life from the moment of conception can be supported in a secular, liberal state. If the answer is that there is some special status accorded to the human embryo or fertilized egg that requires its protection from the moment it is fertilized, feminists argue, this is best characterized as a religious view. If so, religious beliefs are being imported into state laws and the US Constitution that have a disproportionate impact upon women. The vague references to protecting potential life, so central to all the Supreme Court’s decisions on this complex issue, obscure these critical implications and are problematic on many grounds. Even in a modern, secular, liberal state that is explicitly committed to individual freedom, women’s fundamental liberties can be obscured and mystified by language and action that uphold and impose longstanding restrictive modes of thought and custom that may not always be recognized as religious in origin but that have no other plausible explanation. Such restrictions are often expressed in and defended by the use of religious language (such as sacred-ness or sanctity) that is applied to controversial religious doctrines as though they were settled, basic and uncontroversial. 