Third, Luce1 cogently argues against adopting a New Jersey-type “exception” law that prohibits physicians from applying DDNC to religious objectors. But it is far easier to defend “reasonable accommodation” laws such as those in California, Illinois, and New York. Hospitals in these states have not reported that compliance is burdensome. Indeed, the burden of extending such a mandate to other states would be minimal. The duration of accommodation would be limited to just a few hours or days. And these disputes would be rare given the relatively small US population with religious objections (Japanese Shinto, Orthodox Jews, Buddhists, Muslims, and Native Americans).5 Furthermore, most US hospitals already typically offer such accommodation. Consequently, extending a “reasonable accommodation” mandate would simply codify and clarify the prevailing standard of care.