While the scope of protections afforded the unborn is still limited, the States' interests in protecting the potentiality of human life has been recognized through liability in both tort and criminal law. The increased awareness of the effects of maternal substance abuse on the developing fetus has given rise to the need for an extension of fetal rights to protect against this abuse. Maternal cigarette smoking during pregnancy has been associated with low infant birth weights that increase the risk of other disorders such as respiratory distress snydrome, jaundice, and developmental deficiencies. Maternal alcohol use can stop or slow the development of specific cells, cause cell death, or affect cells to the extent that fetal organs and tissues do not function properly. Similarly maternal drug abuse during pregnancy can result in fetal neurological abnormalities and later cognitive and developmental deficits. In addition, there is a connection between maternal drug abuse and AIDS in children. Once a woman has chosen to carry a pregnancy to term, she has an obligation to bring the fetus into the world in as healthy a condition as possible and has, at the same time, placed limits on her freedom over her body. Because a fetus injured by maternal conduct may not have the knowledge or means to vindicate its injury, maternal fetal abuse should be criminalized. 157 footnotes.