Americans often think of Griswold v. Connecticut, which established the ability to use birth control via a right to privacy in 1965, as a gender equality case. But the Supreme Court granted the right to birth control before it established equal protection for gender and before Congress passed the Equal Rights Amendment, Title VII, the right to equal credit, and much more. Birth control helped feminists’ fight for rights, but historians have suggested that it came first because Griswold was not purely a gender equality case.[1] For many Americans, from justices to Planned Parenthood itself, Griswold was a population control case.
“Adherents to the Great Replacement Theory are increasingly violent as seen in the Unite the Right rally in Charlottesville, the grocery store shooting in Buffalo, the Christchurch shooting in New Zealand, and even the January 6 insurrection…”
As historians and legal scholars have shown, policymakers increasingly worried about unchecked population growth particularly among unmarried Black women in the years leading up to Griswold. In a postwar evolution of eugenics thinking, critics argued a population bomb would lead to famine, war, and other disasters. Planned Parenthood itself argued in 1960 that we had to act to “disarm the population bomb.”[2] Congress held the Gruening Hearings on the population crisis in 1965. In the United States, white feminist activists benefited from an alliance with strange bedfellows who were invested in population control rather than gender equality.
But if population panic helped usher in the right to birth control, a new population crisis seems poised to help to take it away. Instead of fearing a world population that is too large, a faction of the right wing has argued that the “American” population or the *white* population within the United States has grown too slowly. Pundits and lawmakers call for limits to immigration and birth control alike as well as encouraging “traditional” families. An AP poll shows that a third of Americans believe that there is a plan to allow immigrants to outnumber native-born Americans.[3] Marjorie Taylor Greene has argued that an “unholy alliance of leftists, capitalists and Zionist supremacists” had the “deliberate aim of breeding us out existence in our homelands.”[4] The Great Replacement Theory is the most extreme example of this fixation. Adherents to the Great Replacement Theory are increasingly violent as seen in the Unite the Right rally in Charlottesville, the grocery store shooting in Buffalo, the Christchurch shooting in New Zealand, and even the January 6 insurrection according to Robert A. Paper.[5]
The leaked Dobbs opinion suggests that even Justice Alito sees population control as a significant problem. Alito’s draft quotes a CDC document bemoaning the low “domestic supply of infants,” a concern seemingly remote from the loss of fetal cells but very aligned with a population panic.[6] Another Alito footnote cited Justice Thomas to argue that abortion has suppressed the Black population.[7] This citation places Alito and Thomas outside of the extreme of Great Replacement Theorists, but population panic is nonetheless a real presence in the draft. In 2022, anyone who can get pregnant stands to suffer from a vastly evolved population panic. Not only the battle for reproductive rights but also anti-racism and anti-nationalism work will be essential going forward.
[1] Ricki Solinger, Wake Up Little Susie: Single Pregnancy and Race before Roe v. Wade (Routledge, 2000); Linda Greenhouse and Reva B. Siegel, “Before (and After) Roe v. Wade: New Questions about Backlash,” The Yale Law Journal 120 (June 2011), 2028-2087; Mary Ziegler, Reproduction and the Constitution in the United States (Routledge, 2022); Betsy Hartman, Reproductive Rights and Wrongs: The Global Politics of Population Control (Haymarket Books, 2016).
[2] Andrea Smith, “Beyond Pro-Choice versus Pro-Life: Women of Color and Reproductive Justice,” NWSA Journal 17 (Spring 2005), 132.
[3] AP-NORC Center for Public Affairs Research, “Immigration Attitudes and Conspiratorial Thinkers: A Study Issued on the 10th Anniversary of the Associated Press-NORC Center for Public Affairs Research,” APNORC, May 9, 2022, https://apnorc.org/projects/immigration-attitudes-and-conspiratorial-thinkers/.
[4] Talia Lavin, “The Buffalo Shooter Isn’t a ‘Lone Wolf.’ He’s a Mainstream Republican,” Rolling Stone, May 15, 2022, https://www.rollingstone.com/politics/political-commentary/buffalo-shooter-white-supremacist-great-replacement-donald-trump-1353509/
[5] Robert A. Paper, “The Jan. 6 Insurrectionists Aren’t Who You Think They Are,” Foreign Policy, January 6, 2022,
[6] SCOTUS Initial Draft, Contributed by Politico Staff, February 10, 2022, 34, https://www.documentcloud.org/documents/21835435-scotus-initial-draft
[7] SCOTUS Initial Draft, Contributed by Politico Staff, February 10, 2022, 30, https://www.documentcloud.org/documents/21835435-scotus-initial-draft