United States v. One Package

In 1937, the American Medical Association (AMA) finally reversed its long-held refusal to study contraception and began to support state and federal reforms. As Sanger biographer Ellen Chesler has written, the AMA regarded birth control "as a responsible element of normal sexual hygiene in married life. To this end, it recommended that the subject be taught in medical schools, that scientific investigation of various commercial materials and methods be promoted, and finally that the legal rights of physicians in relation to the use of contraceptives be clarified."

Although the birth control movement claimed victory in United States v. One Package, not until 1971 would Congress rewrite the Comstock law to remove the specific mention of birth control material. The use of contraceptive devices--even for married couples--remained illegal until 1965, when the Supreme Court overturned the laws in 1964 with Griswold v. Connecticut. In 1972, the Court made the use of contraceptive items lawful for single people as well in Eisenstadt v. Baird.