California, United States of America
The following excerpt is from Justus v. Atchison, 126 Cal.Rptr. 150, 53 Cal.App.3d 556 (Cal. App. 1975):
3 A modern view has been stated in O'Neill v. Morse (1971) 385 Mich. 130, 188 N.W.2d 785, 787: 'The phenomenon of birth is not the beginning of life; it is merely a change in the form of life.'
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