In the Phoenix case, pulmonary hypertension threatened the life of an eleven-week pregnant mother. Removal of the placenta as the organ threatening the mother’s life necessarily included extracting the amniotic membranes containing the fetus. The author proposes this argument: the principle of double effect clarifies that causing the death of the fetus (destined to die, whatever transpired) while avoiding a direct physical assault on it constitutes an indirect and unintended (albeit foreseen) side effect, thereby justifying the intervention