First, you suggest that the understanding of “health” that I put forth, as a scientific term with an objective meaning, is mistaken and should be replaced with an understanding of “health” as autonomy that has only a subjective meaning. That is, you argue that “health” is “what each person sees as the proper functioning of their own body as an integral aspect of their self.”

So it seems to me O’Callaghan is attributing to Breen a position that Breen has repudiated.

However, I do think that Breen’s original argument—that given his preferred definitions of health and health care, contraception has no place in laws dealing with health care coverage—is a weak one. If, for the purposes of legislation, legislators include something in a bill as health care, then legally speaking it is health care. The legislators’ understanding (to the extent it is known) of statutes they write is what determines how the statutes will be interpreted.