Christine Durham, Chief Justice of the Utah Supreme Court through 2012, is the most recent in a long line of pro-choice Latter-day Saints to fundamentally misconstrue the Church's adamant opposition to abortion as something other than pro-life. The problem is not that Durham gets the Church's position wrong. She correctly notes that the Church does not consider abortion to be murder and that the Church acknowledges certain rare, exceptional cases where abortion may be legally and morally justified. The problem is that, contrary to Durham's assertions, these positions fit comfortably within the mainstream of the pro-life movement.