Assessing the grim toll of the massacre in Sutherland Springs, Tex., sheriff’s deputies found 22 of the bodies inside the First Baptist Church, but by their reasoning, one more victim died there — inside the womb of Crystal Holcombe, who was killed in the pews along with three of her five children.

Texas is one of at least 38 states with a law that recognizes a fetus in utero as a potential crime victim separate from the mother, or where stiffer penalties apply when crimes are committed against pregnant women. Federal law recognizes unborn fetuses as separate victims of federal and military crimes.

The laws, some recent and others decades old, are another battle front in the long, passionate political war over abortion and the question of when life begins. Anti-abortion groups have lobbied for fetal homicide laws as part of a broader campaign for “personhood,” hoping to persuade the public to regard prenatal life at any stage of development as a human being deserving of legal rights and protection.

The federal Unborn Victims of Violence Act of 2004 took five years to get through Congress. It gained momentum after the killing in California of Laci Peterson, who was eight months pregnant. Her husband, Scott Peterson, was convicted in 2004 of two counts of murder, one for his wife and one for the unborn child she was carrying.