MEANS TO AN END

This is very old, but:

U.S. Denies Patent for a Too-Human Hybrid

Patents on humans could also conflict with the 13th Amendment’s prohibition against slavery. That is because a patent permits the owner to exclude others from “using” the invention. Because “use” can mean “employ,” officials wrote, a patent holder could prevent a person from being employed by any other — which “would be tantamount to involuntary servitude.”