The Means Case: Medical Ethics and the USCCB

By Mike Appleton, Weekend Contributor

“In this case, a young woman in a crisis situation was put at risk because religious directives were allowed to interfere with her medical care. Patients should not be forced to suffer because of a hospital’s religious affiliation.”

-Kary Moss, executive director, ACLU of Michigan (quoted in the Detroit Free Press, December 2, 2013)

“The Church holds that all human life, both before and after birth, has inherent dignity, and that health care providers have the corresponding duty to respect the dignity of all their patients. This lawsuit argues that it is legally ‘negligent’ for the Catholic bishops to proclaim this core teaching of our faith. Thus, the suit urges the government to punish that proclamation with civil liability, a clear violation of the First Amendment.”

Archbishop Joseph Kurtz, president, U.S. Conference of Catholic Bishops (quoted in the National Catholic Register, December 7, 2013)

Tamesha Means was only 18 weeks pregnant when her water broke. A friend rushed her to the emergency room at Mercy Health Partners in Muskegon, Michigan. She was examined and sent home with instructions to follow up with her regular doctor at her next scheduled appointment. The following morning she returned to the hospital, bleeding and having painful contractions. She was given pain medication and again sent home. That very night she returned for the third time, in great pain and with an elevated temperature, suggestive of an infection. As the hospital was preparing paperwork to send her home yet again, Ms. Means went into labor and delivered a baby who survived fewer than three hours. She was then informed that she would need to make funeral arrangements.

Those are a few of the allegations contained in a new lawsuit that has outraged conservatives and the Catholic hierarchy by advancing traditional negligence principles as a basis for imposing liability against a surprising group of defendants. 

The suit alleges negligence, but the targets are not the hospital, the treating physicians or the medical staff. Instead, the named defendants are the current and two former chairpersons of Catholic Health Ministries, an unincorporated association formed pursuant to Catholic canon law, and the United States Conference of Catholic Bishops, a non-profit corporation whose members include all Catholic bishops in the United States and the U.S. Virgin Islands.

Ms. Means claims that Catholic Health Ministries and the USCCB effectively prevented her from learning the truth about her medical condition, the consequent risks to her health and to the development of the fetus, and the treatment options lawfully available to her. More specifically, she asserts that she was not informed that the premature rupture of her membranes had made it virtually certain that the fetus would not survive, that continuing her pregnancy increased the risk of serious bacterial infection, possibly resulting in infertility or even death, or that inducing labor and terminating the pregnancy is a medically acceptable treatment under such circumstances. Lab tests performed following the miscarriage in fact confirmed that Ms. Means had developed acute chorioamnionitis and acute funisitis prior to going into labor.

The complaint reads much like a standard claim of medical malpractice. So why did Ms. Means elect not to sue the medical providers? And how can she link her unnecessary suffering and mental anguish to Catholic Health Ministries and the USCCB? In response to the first question, it has been suggested that the relevant statute of limitations barred a malpractice suit. But that explanation does not address the second question. And the critics have been harsh. The editors of National Review Online labeled the case “a gross violation of the First Amendment and a despicable political gambit” by the ACLU “to force Catholic organizations not only to subsidize abortions but to perform them as well.” Writing in the Washington Times, Robert Knight made the same accusation, but added, “Since only the Catholic Church bothered to build a hospital within 30 minutes of Ms. Means’ home, the ACLU contends that the facility should operate without religious principles guiding it or simply switch to the ACLU’s brand of moral relativism, where unborn children are merely options.” And in an opinion piece in the New York Post, Seth Lipsky declared, “Welcome to the next front in the war against religion.” He also suggested that perhaps the ACLU should sue the pope.

Either the critics have not taken the time to thoroughly review the lawsuit or they are merely repeating the frequently heard but nonsensical accusation that disagreement with the actions or policies of a religious organization is an assault on religious freedom. Or perhaps it’s both. In any event, the critics are wrong.

In order to understand the case, it is necessary to understand the relationships among the defendants and the impact of a document entitled Ethical and Religious Directives for Catholic Health Care Services, a set of written directives published by the USCCB and revised from time to time. Catholic Health Services is the Catholic sponsor of Trinity Health, a Catholic healthcare system that assumed the operations of Mercy Health Partners in Muskegon following a merger in 2008. Trinity’s corporate governing documents provide that it will conduct its business in accordance with Catholic teaching, including the USCCB directives.

The USCCB directives, now in their fifth edition, describe the role of the Catholic Church in its “ecclesial mission of health care” and set out 72 directives in 6 sections for making spiritual, pastoral and medical decisions in the provision of health care services. And, as one would expect, the directives are intended to be binding on Catholic hospitals. The preamble calls the directives “prescriptive.” Directive 5 should eliminate any confusion in that regard. It reads, “Catholic health care services must adopt these Directives as policy, require adherence to them within the institution as a condition for medical privileges and employment, and provide appropriate instruction regarding the Directives for administration, medical and nursing staff, and other personnel.” Directive 9 states in part, “Employees of a Catholic health care institution must respect and uphold the religious mission of the institution and adhere to these directives.” There are no exceptions for non-Catholic employees.

In sum, the USCCB has promulgated a set of rules intended to be binding on all Catholic health care facilities and all of their employees. Physicians who fail to comply risk the loss of admitting privileges. Employees who fail to comply risk the loss of employment. And the penalties have been enforced. Several years ago Sister Margaret McBride, the administrator at St. Joseph’s Hospital and Medical Center in Phoenix, was declared excommunicated by her bishop for approving an ethics committee recommendation to terminate the pregnancy of a 27-year-old mother of three diagnosed with pulmonary hypertension. She was 11 weeks pregnant when she was admitted and her death was deemed a virtual certainty should her pregnancy continue. A cardiologist at a Catholic hospital in Durango, Colorado was disciplined last year for merely discussing the possibility of an abortion with a pregnant patient who had a serious cardiovascular condition known as Marfan syndrome, a disorder which can cause an aorta to rupture.

Of special significance in the Means case are Directives 27 and 45. Directive 27 appears in a section devoted to the professional-patient relationship. That section acknowledges the critical importance of “mutual respect, trust, honesty, and appropriate confidentiality” as elements of that relationship. Directive 26 stresses the necessity of “free and informed consent” to all medical procedures. Directive 27 provides, “Free and informed consent requires that the person or the person’s surrogate receive all reasonable information about the essential nature of the proposed treatment and its benefits; its risks, side-effects, consequences, and cost; and any reasonable and morally legitimate alternatives, including no treatment at all.” The operative phrase here is “morally legitimate.”

Directive 45 is a restatement of the Catholic position on abortion. “Abortion (that is, the directly intended termination of pregnancy before viability or the directly intended destruction of a viable fetus) is never permitted. Every procedure whose sole immediate effect is the termination of pregnancy before viability is an abortion, which, in its moral context, includes the interval between conception and implantation of the embryo.” It is when Directives 27 and 45 are read together that the conflict at the heart of the Means case becomes clear. It was not the refusal of Mercy Health Partners to provide abortion services that constituted the breach of duty alleged in the complaint, but the failure to inform Ms. Means of the option of abortion. Although responsive pleadings have not been filed to date (a motion for change of venue is pending), the bishops will undoubtedly argue that the duty alleged by Ms. Means does not exist because a Catholic hospital may not be compelled to provide information to patients regarding treatment or procedures which are not “morally legitimate” or which would violate the moral principle of “material cooperation.”

Directive 27 turns the notion of freedom of religion on its ears because it means that a patient in a Catholic hospital is required to abandon his or her own religious views on the floor of the admissions office. But don’t non-Catholic patients in Catholic hospitals understand this? I doubt that the subtleties of “informed consent” are explained in the emergency room. So why not go to a different hospital? In its retort to the audacity of the ACLU, National Review Online made that point. “But it does not seem to have occurred to them that if they don’t like Catholic hospitals, they should go somewhere else.”

That observation is long on snark and impertinence, but short on reality. There are two hospitals in Muskegon County, Michigan providing acute care and emergency room services: Mercy Health Partners-Mercy Campus and Mercy Health Partners-Hackley Campus. Following its merger last year with Catholic Health East in Pennsylvania, the Trinity Health system is one of the largest in the country, with a presence in 21 states. According to the 2011 American Hospital Association Annual Survey, there were 630 Catholic hospitals in the United States. Catholic hospitals care for one out of every six patients in the United States, and account for 16.5% of Medicare discharges and 13.7% of Medicaid discharges. Moreover, perhaps as a consequence of the traditional commitment of the Church to the poor and the uninsured, 32% of Catholic hospitals are located in rural counties. For these patients, as for Ms. Means, the invitation to “go somewhere else” is meaningless.

And this brings us to the issue of proximate cause. Assuming the truth of the allegations in the complaint, it is clear that Mercy Health  Partners failed in its obligation to furnish Ms. Means all of the information to which she was lawfully entitled in order to make an informed decision concerning her own medical treatment. But what duty, if any, did the USCCB owe to her? Prof. Cathleen Kaveny, an acknowledged expert in law, moral theology and medical ethics, contends that there is no causal relationship whatsoever between the USCCB’s adoption of the directives and the injuries suffered by Ms. Means because they are enforceable only to the extent a health care facility contractually undertakes to comply with them. Under this view, the USCCB occupies a position similar to, say, the National Conference of Commissioners   on Uniform State Laws. It makes proposals, but lacks the legal authority to impose them.

I disagree with Prof. Kaveny because her opinion on the issue of proximate cause ignores the compelling moral force of the directives for any health care facility that wishes to declare itself Catholic. Moral theology is not an abstract academic enterprise; it is intended to inform real life decisions about real life problems. Furthermore, it cannot be seriously disputed that the directives have been promulgated with the expectation that they will be accepted and followed as the authoritative teaching of the American Catholic hierarchy. In issuing the directives, the bishops certainly knew that they would be formally adopted by Catholic hospitals and that the patients in those hospitals would be subjected to their requirements. Having determined to draft and publish the directives, the USCCB assumed a duty of care toward those who would forseeably be directly affected by their implementation. That duty extended to Ms. Means. (Prof. Kaveny also believes that the hospital misinterpreted the directives in the Means case, but that is a separate topic for another time).

Regardless of the outcome of the Means case, it properly focuses attention once again on taxpayer support of religious institutions in the performance of ostensibly secular functions. In Bradfield v. Roberts, 175 U.S. 291 (1899), Congress appropriated $30,000.00 for the construction of two isolation wings at Providence Hospital, a Catholic facility operated by the Sisters of Charity. The units were intended for the care of indigent patients under a contract between the hospital and the District of Columbia. The issue was whether the appropriation violated the Establishment Clause. It did not, declared the court, because the hospital was a secular corporation rather than a religious body. “It is simply a case of a secular corporation being managed by people who hold to the doctrine of the Roman Catholic Church, but who nevertheless are managing the corporation according to the law under which it exists.” 175 U.S. 298-99. The decision was unanimous.

We have come a long way since the Bradfield decision, the first case to test the constitutionality of public funding of a sectarian hospital. And the issues are now far more complicated. The Means case questions the extent to which religious doctrine may permissibly govern the performance of a secular function by a health care facility supported in part by public funds before the Establishment Clause is implicated. But perhaps we should be asking a different question. If the Catholic Church defines the operation of hospitals as “the ecclesial mission of health care,” can any public funding of those facilities satisfy the tests in Lemon v. Kurtzman, 403 U.S. 602 (1971)? Perhaps there is truth in the observation of Dr. Marie T. Hilliard of the National Catholic Bioethics Center that ” there is a need to correct the misperception that the delivery of health care is a secular endeavor.” If that is the case, the Means case could be significant indeed.

257 thoughts on “The Means Case: Medical Ethics and the USCCB”

  1. Elaine, when I read the things David writes, it makes me so relieved that I was able to break free and raise my own daughters as free women.

  2. annie,

    Atwood’s “The Handmaid’s Tale”–was an excellent and chilling book to read. There are some among us who would like to see our country become a Christian theocracy.

  3. Not only Fundamentalists, The Catholic Bishops. A statement should be made to be prominently displayed on a bronze plaque near the main entrance to the hospital. “Warning, we treat our patients according to our interpretation of the Bible.”

  4. annieofowl, Yep….. A Rand Paul or Ted Cruz presidency would pretty much guarantee it.

  5. David seems to be the arbiter of appropriate behavior, based on what? What makes David so certain he is right? By what authority has he vested himself?

    My suspicion is that he has taken a Fundamentaliat interpretation of the Bible, and run with it. I also suspect that these Fundamentalists would do whatever they could to impose their own moralistic view onto people who do not believe as they do, because they are SO convinced they are right and are imbued with the authority of God himself. I know all too well the Fundamentalist’s world view, having grown up in an Assemblies of God church. Most young people I grew up with in that church, eventually rebelled and turned their backs on such Christian extremism.

    His views are a preview of tomorrow’s world under the rule of The Christian Theocracy. The Handmaid’s Tale and A Christian Nation, a warning.

  6. davidm,

    I didn’t mischaracterize anything you said. Keep trying to spin.

    If you want to grow in your understanding, try opening your mind…try to think about what it might be like to be a woman with a troubled pregnancy that could cause her medical complications/risk her life…try to look at women as equals…try to have more respect for the opposite sex.

  7. David, excuse me? First of all it was a statement made in jest to reflect the absurdity of your opinion on human sexuality and reproduction. Really, you do cast aspertions on women who don’t conform to your very narrow world view, dont you? I don’t think you have the right to tell any woman how she may (or should) behave unless she is part of your family and she tolerates it, which is sort of sad, but it’s none of my business.

    I can just see some son telling his mother, “Hey Ma, got back to yer knitten’ quit being a sex kitten!” 😀

  8. davidm2575

    Elaine M wrote: “in the world according to davidm, one should only experience sexual pleasure if one is not trying to prevent pregnancy during intercourse…one should only have sex to procreate…one should not use birth control…women should be willing to get pregnant every time they have sexual relations.”

    You are not framing the questions correctly that would lead you to understand natural law and how it relates to our reproductive function.


    There are no questions in what I wrote. I’m just paraphrasing what you said…in condensed language.

    1. Elaine M wrote: “There are no questions in what I wrote. I’m just paraphrasing what you said…in condensed language.”

      That’s what I said, that you are not framing the questions correctly. Issues are resolved by asking the right questions, and framing questions in a way that can lead to resolution. You are not doing that.

      Instead of attempting to understand the issue, you mischaracterize what I have said and call it paraphrasing what I said. I say that pleasure is a built-in natural aspect of sex, but blocking other aspects to make sex only about pleasure is inappropriate, and you represent me to say one should only have sex to procreate. That’s like me saying that pleasure is a built-in natural aspect of eating food and that blocking the nutritional value of food to make eating only about pleasure is inappropriate, then you come along and claim that I said one should eat only for the nutritional value of food. It is a non sequitur and adds nothing to understanding. If you want to grow in your understanding, try framing the right questions.

  9. Elaine,

    But for the costs of this type of case…. The recovery if successful will be maxed at about 280k …. I think the hospital is grossly negligent…. This lady could have gone home and died…. At that age, I understand that the fetus was not viable…. Any other hospital would have preformed the necessary services to dead with this…. It’s possible now that the lady will never be able to have children again….. Maybe that’s a factor….in negligence…. But in this area of Michigan….. I think it will be hard pressed….

    What David does not get… Is this was not about choice but proper treatment of the lady’s medical condition….

    But, none is smarter than him….

    1. AY wrote: “I think the hospital is grossly negligent…”

      Then why isn’t the ACLU suing the hospital?

      AY wrote: “Any other hospital would have preformed the necessary services to dead with this…”

      I assume you mean that they would have performed an abortion? Not according to the physician guidelines which I posted previously.

      AY wrote: “It’s possible now that the lady will never be able to have children again…”

      Unlikely, but even if this or death were the outcome, why would not the physicians guidelines for PROM call for an immediate abortion? Do you know better than all the physicians?

      AY wrote: “What David does not get… Is this was not about choice but proper treatment of the lady’s medical condition…”

      If this was really what this case was about, they would have sued the hospital and doctors. They did not do that. There is no case there because the physicians appeared to have followed the normal physician procedures in case of PROM. What the ACLU is doing is trying to force Bishops in the church to advise patients that they have the option to choose abortion in difficult pregnancies. If you took away advocacy for abortion, there would be no lawsuit here.

      Incidentally, doctors make more money performing the abortion option, and it is much more convenient for them as well because it happens according to their time schedule. I don’t think this motivates the ACLU, but it would make it easy for them to find abortionist doctors to testify for them.

  10. ACLU Sues Catholic Bishops for Refusing Treatment to Miscarrying Woman
    By Amanda Marcotte

    As anti-abortion sentiment grows more extreme, it’s inevitable that it will start to interfere with the ability of women to get medical care even when they’re losing wanted pregnancies. In El Salvador, the eagerness to arrest women caught illegally aborting has led to the government charging women who have miscarried wanted pregnancies with murder. In Ireland, Savita Halappanavar lost her life when doctors refused to clear out a miscarrying pregnancy, even though it was clearly turning septic. These doctors decided, under Ireland’s strict abortion ban, that giving Halappanavar’s fetus an opportunity to experience a few days more of a heartbeat was more important than saving Halappanavar’s life.

    While the United States has much more liberal abortion laws than Ireland and El Salvador, this extremism is affecting women’s medical care here, too. Catholic hospitals, which constitute 12 percent of hospital in the U.S., usually require doctors to refuse to help a woman who is miscarrying until the fetal heartbeat stops on its own, which is the same rule that led to Halappanavar’s death. The American Civil Liberties Union is now suing the United States Conference of Catholic Bishops on behalf of Tamesha Means, who went to the only hospital in her area—Mercy Health Partners in Muskegon, Mich.—for help with a clearly miscarrying pregnancy. Twice, the misleadingly named Mercy hospital sent Means home, despite her suffering…

    Despite anti-abortion activists’ claims that they see both the mother and the fetus as equally deserving of life, the refusal to treat miscarrying women as long as the fetus can manage a couple of heartbeats demonstrates how untrue that is. If a pregnancy cannot be saved, refusing treatment quite clearly means prioritizing the fetus—it means choosing a couple more hours for the fetus over relieving a woman’s suffering; saving her health; and, in some cases, saving her life. The directive to refuse care in these cases demonstrates how little the anti-choice movement is actually about “life,” something conscious women clearly have, and we should all care about protecting.

  11. annie,

    Resign yourself. Women are only good for one thing–bringing children into the world. Well, maybe, they are also go for some other things: cooking, cleaning, food shopping, doing laundry, ironing, serving the men in their lives…and knitting when they are beyond their childbearing years.

  12. Oh heck! Ya mean I have to cut off my gentleman friend because we are beyond our childbearing years? Or maybe he could find a young woman to have children with and old women like me could just wear widows weeds and knit.

    1. Annie wrote: “Ya mean I have to cut off my gentleman friend because we are beyond our childbearing years? Or maybe he could find a young woman to have children with and old women like me could just wear widows weeds and knit.”

      You talk as if your life without sex with your gentleman friend would be meaningless. How sad. Life is about so much more than sex. There is so much more that women are capable of, especially in their elder years.

  13. davidm2575

    Elaine M wrote: “If people have sex for pleasure you feel that’s immoral?”

    No, you missed the point. Pleasure is a built-in natural aspect of sex. What is immoral is blocking another built-in natural aspect of sex in order to make sex ONLY about pleasure. The perversion of natural function is immoral. A person cutting himself is immoral because it is contrary to natural law.


    So…in the world according to davidm, one should only experience sexual pleasure if one is not trying to prevent pregnancy during intercourse…one should only have sex to procreate…one should not use birth control…women should be willing to get pregnant every time they have sexual relations.

    I’m glad I live in a world different from the one that would be your Utopia.

    1. Elaine M wrote: “in the world according to davidm, one should only experience sexual pleasure if one is not trying to prevent pregnancy during intercourse…one should only have sex to procreate…one should not use birth control…women should be willing to get pregnant every time they have sexual relations.”

      You are not framing the questions correctly that would lead you to understand natural law and how it relates to our reproductive function.

      Look at it from the perspective of what causes the hurt and heartache around relationships involving a couple having sex. Take the case of a teenage girl who really likes a teenage boy. Part of our culture teaches her to be sexual with him because he likes it and will like her if she does. It teaches “responsible sex” by teaching ways to block the reproductive nature of sex. It gives her hormone pills to trick the natural laws working within her body, blocking the reproductive laws at work. It gives her condoms for the same purpose, and also to work toward blocking the venereal diseases that become a problem when she engages in that type of lifestyle of casual sex. None of these barriers to natural law are 100% effective, so a day comes when she is unexpectedly pregnant. Now she is distraught and confused. How did this happen? She did all the right things with birth control. So her next step is to get an abortion because she is not ready for the responsibility of parenthood. Being a busy person, she waits longer than she should and so when she finally does do the abortion, she is basically induced to have a miscarriage. It is a gruelling experience of labor followed with lots of blood and body parts being expelled from her body. She had been told that it was only a fetus, a part of her body that would be removed easily to terminate her pregnancy, but faced with the reality of it, she can see it is an unborn baby. The memories and thought of the event haunts her. Now she has to undergo the psychological issues of the fact that she murdered her unborn baby. She is comforted by people telling her that it was not murder, that her unborn baby is not really a baby, but deep down, another natural law is at work within her, her maternal instincts to love and cherish her child, and yet she did the very opposite thing and she realizes that she has thwarted that purpose for her life.

      As the rational mind examines this type of scenario and all the associated hurt and pain caused in this life, how can one escape the understanding that the problems all stem from the basic root cause of trying to live contrary to natural law? If instead of trying to thwart natural law, what if she had embraced it? Would not her life have been happier? What if she saw motherhood as a next step in life, as entering adulthood in a responsible way. What if she saw becoming pregnant as a wonderful and joyous event? What if she saw her natural ability to carry a baby to term as the greatest gift she could give to the man she loves? If she saw all the natural laws at play as good and something to cooperate with, if she entered into a marriage relationship with this recognition, and welcomed the natural laws that would enable them to bring a new life into the world, would not all of these events have taken on tremendous goodness? The joy in her life would be so much better than all the pain caused by the other path which conducted itself in a manner contrary to natural law.

  14. I wonder, if David’s wife would have serious complications at home during childbirth because David doesn’t trust hospitals, who will be at fault here? Will his poor wife deserve what she got because she put her trust in him?

  15. on 1, February 13, 2014 at 2:44 pmdavidm2575
    AY wrote: “Now, what would you do f this was your wife or daughter…..?”

    “Seriously, that is your question? I would tell her that she deserves whatever she gets when she decides to put her trust in a particular doctor or hospital. The hospital did not cause your membranes to rupture, and they did what they could to protect both your life and the life of your baby. That’s exactly how I read this situation, and exactly what I would tell her.

    The thing you may not realize, however, is that I inherently do not trust the medical community. Many people look at doctors like a god. Not me. My perspective is that they are fallible people like the rest of us, and believe me, I have taught enough pre-med students vertebrate anatomy that I think twice about trusting them. I believe that I have a choice of whether to trust a doctor or hospital or not. I consider artificial birth control to be immoral in that it operates contrary to natural law. When my wife becomes pregnant, I don’t hire anybody. I deliver my children at home. Nobody is going to care for my wife and child like I will. If there was an emergency situation where I believed that the knowledge of the doctors might help save the life of either my wife or my unborn child, I might go to the hospital like Tamesha did, but I would never sue them if they failed to be able to help me. If doctors fail, my recourse is to not go to them next time, the same way I do not return to an auto mechanic or retail store that has violated my trust.”

  16. So David, just one example. a woman I know has had 8 miscarriages. She has been told that she cannot get pregnant again as even a miscarriage may cause her to bleed to death. You say ” Pleasure is a built-in natural aspect of sex. What is immoral is blocking another built-in natural aspect of sex in order to make sex ONLY about pleasure. The perversion of natural function is immoral. A person cutting himself is immoral because it is contrary to natural law.” Under your belief, she and her husband would now have to live platonically only. Birth control is immoral and apparently so too would be vasectomy (not 100% foolproof) or sterilization.
    In your world things are truly black and white.

    1. leejcaroll wrote: “In your world things are truly black and white.”

      I realize that liberals love to celebrate greyness, but you might consider that such is often a cloak for celebrating ignorance. It is a truism that in virtually every field, not just science, mathematics, and technology, but also economics, religion, and politics, the more knowledge and understanding a person has about a particular problem, the more black and white is the answer to the problem.

  17. And David, when you wrote upthread somwhere when asked by someone what you would do if you were this woman’s father, you said you would’ve told her she DESERVED what she got, well that said a lot about you.

    1. Annie wrote: “when asked by someone what you would do if you were this woman’s father, you said you would’ve told her she DESERVED what she got, well that said a lot about you.”

      That is not exactly what I said, but your reaction to what I said says a lot about you as well. A difference here is that I will not put you on trial the way you have done with me. It is not good for you to usurp the authority of being a Judge over another person.

  18. David, you cast aspertions and judgments on women (feminists and lesbians) you do not know. You cast aspertions and judgements on gay people you don’t know. Thinking rational, fair minded people do not have to put up with your ideologically fallacious talk without calling you on it. My criticisms are not necessarily personal to you, I react to what you write here only.

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