One of the most significant developments in the area of reproductive health in Ireland is theRoche v. Roche[2009] case. The case concerned a woman who wished to implant cryopreserved embryos made with a former partner, against the partner’s wishes. Of particular interest are questions about the status of the embryo: in Ireland the life of “the unborn” is constitutionally protected. Therefore the courts inRochehad to decide whether embryos were “unborn” within the meaning of the Irish Constitution.