In Gonzales v. Carhart,148 Justice Anthony Kennedy, writing for the US Supreme Court, said that the State "has respect for human life at all stages in the pregnancy" and "a legitimate and substantial interest in preserving and promoting fetal life." Invariably, in the decision, the fetus was referred to, or cited, as a baby or a child. 149 Intent of the Framers Records of the Constitutional Convention also shed light on the intention of the Framers regarding the term "conception" used in Section 12, Article II of the Constitution. From their deliberations, it clearly refers to the moment of "fertilization." The records reflect the following: Rev. Rigos: In Section 9, page 3, there is a sentence which reads: "The State shall equally protect the life of the mother and the life of the unborn from the moment of conception." When is the moment of conception? xxx Mr. Villegas: As I explained in the sponsorship speech, it is when the ovum is fertilized by the sperm that there is human life. x x x.150 xxx As to why conception is reckoned from fertilization and, as such, the beginning of human life, it was explained: Mr. Villegas: I propose to review this issue in a biological manner. The first question that needs to be answered is: Is the fertilized ovum alive? Biologically categorically says yes, the fertilized ovum is alive. First of all, like all living organisms, it takes in nutrients which it processes by itself. It begins doing this upon fertilization. Secondly, as it takes in these nutrients, it grows from within. Thirdly, it multiplies itself at a geometric rate in the continuous process of cell division. All these processes are vital signs of life. Therefore, there is no question that biologically the fertilized ovum has life. The second question: Is it human? Genetics gives an equally categorical "yes." At the moment of conception, the nuclei of the ovum and the sperm rupture. As this happens 23 chromosomes from the ovum combine with 23 chromosomes of the sperm to form a total of 46 chromosomes. A chromosome count of 46 is found only - and I repeat, only in human cells. Therefore, the fertilized ovum is human. Since these questions have been answered affirmatively, we must conclude that if the fertilized ovum is both alive and human, then, as night follows day, it must be human life. Its nature is human.151