The Alabama Supreme Court ruled last month that frozen embryos, commonly used for In-Vitro Fertility (IVF) treatments are considered children under the Alabama constitution. This ruling has caused significant unease among fertility clinics in Alabama and those in states with other staunch pro-life states. To make matters worse, the court did not specifically provide a road map as to how fertility clinics may operate in order to avoid civil monetary damages or potentially criminal prosecution under state statute. While it is too early for panic in other states, fertility clinics in Alabama and other pro-life states should pay close attention to the ruling and the actions within their states in the near future to observe how states choose to apply their anti-abortion legislation.