Ann. § 2608 (exempting pregnant women from liability "in regards to crimes against her unborn child”); Tex. Penal Code Ann. § 19.06(1) (exempting the woman from liability for "death of an unborn child”); Utah Code Ann. § 76-7-314.5(2) ("A woman is not criminally liable for (a) seeking to obtain, or obtaining, an abortion that is permitted by this part; or (b) a physician’s failure to com ply [with specified statutes.]”); Vt. Stat. Ann. tit. 13 § 101 (“However, the woman whose miscarriage is caused or attempted shall not be liable to the penalties prescribed by this section.”); Wis. Stat. Ann. § 940.13 (providing no fine or imprisonment for a woman who obtains an abortion or violates any provision of an abortion statute). 4 . See e.g., State v. Ashley, 701 So.2d 338, 340 (Fla. 1997) (<HOLDING>); State v. Aiwohi, 109 Hawai’i 115, 123 P.3d
holding for purposes of establishing the offense of reckless manslaughter against a pregnant woman a fetus is not a person holding that immunity is not waived for injury or death caused by negligent supervision holding that a woman possessed immunity from criminal prosecution for causing injury or death to her fetus holding a fetus is not a child person or individual for purposes of criminal prosecution under the reckless injury to a child statute holding that the definition of person in the hawaii manslaughter statute did not include a fetus and thus did not apply when a woman caused the death of her fetus by smoking crystal methamphetamine