Analysts suspected that Obama would face a battle over abortion if and when he makes a nomination to the U.S. Supreme Court, but religious conservatives could use Sebelius as a warm-up for the seemingly inevitable fight. Calling Sebelius an "enemy of the unborn," Catholic League President Bill Donohue said the Kansas governor's nomination is particularly disturbing because the health and human services secretary is one of the few members of the administration who can directly affect abortion policy. "Sebelius' support for abortion is so far off the charts that she has been publicly criticized by the last three archbishops of Kansas City," Donohue said in a statement.