open. Police raid the clinic and all three women are convicted of disseminating birth control information. Undaunted, Sanger founds The Birth Control Review, the first scientific journal devoted to contraception. She also appeals her conviction, which leads to a new, liberalized interpretation of New York's anti-contraception statute. In 1923 Sanger opens the Birth Control Clinical Research Bureau in Manhattan to provide contraceptive devices to women and collect accurate statistics to prove their safety and long-term effectiveness. That same year, Sanger incorporates the American Birth Control League, an ambitious new organization that embraces the global issues of world population growth, disarmament, and world famine. The two organizations subsequently merge, and later become Planned Parenthood® Federation of America, Inc. (PPFA®). Early Triumphs In 1936 Sanger and other birth control proponents win their first major judicial victory. Sanger is arrested after leaking information to postal authorities that she illegally ordered birth control products through the mail. Her case triggers a review of the issue by the courts. Judge Augustus Hand, writing for the U.S. Circuit Court of Appeals, orders a sweeping liberalization of federal Comstock laws, ruling that contemporary data on the damages of unplanned pregnancy and the benefits of contraception mean that contraceptive devices and birth control could no longer be classified as obscene. Because Judge Hand's decision applies only to New York, Connecticut, and Vermont, it is almost 30 years before married couples throughout the country have the right to obtain contraceptives from licensed physicians. Two other early victories for women's health come one year later:
The American Medical Association officially recognizes birth control as an integral part of medical practice and education. North Carolina becomes the first state to recognize birth control as a public health measure and to provide contraceptive services to indigent mothers through its public health program.