In 1973 the U.S. Supreme Court in Roe v. Wade recognized a constitutional right to abortion, leading to widespread legalization of the procedure, and Comstock fell further out of use.

“I teach reproductive rights and I always teach Comstock early in the course as this historical thing that nobody knows about and to not forget about, but not that I thought it was going to be relevant again,” said Joanna Grossman, a visiting law professor at Stanford University.