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Margaret Higgins Sanger advocated for birth control in the United States and Europe during the late nineteenth and early twentieth centuries. Although people used contraceptives prior to the twentieth century, in the US the 1873 Comstock Act made the distribution of information relating to the use of contraceptives illegal, and similar state-level Comstock laws also classified discussion and dissemination of contraceptives as illegal.
In the 1973 case of Roe v. Wade, the US Supreme Court ruled that laws banning abortion violated the US Constitution. The Texas abortion laws, articles 1191–1194, and 1196 of the Texas penal code, made abortion illegal and criminalized those who performed or facilitated the procedure. Prior to Roe v. Wade, most states heavily regulated or banned abortions. The US Supreme Court decision in Roe v. Wade secured women's rights to terminate pregnancies for any reasons within the first trimester of pregnancy.