The sale and distribution of obscene materials had been prohibited prior to Comstock in most American states since the early 19th century, and by federal law since 1873. Federal anti-obscenity laws are currently still in effect and enforced, though the definition of obscenity has changed much (now expressed in the Miller Test) and extensive debates on what is obscene continue.
In 1915, architect William Sanger was charged under the New York law against disseminating contraceptive information. In 1918, his wife Margaret Sanger was similarly charged. On appeal, her conviction was reversed on the grounds that contraceptive devices could legally be promoted for the cure and prevention of disease.
The prohibition of devices advertised for the explicit purpose of birth control was not overturned for another eighteen years. During World War I, U.S. Servicemen were the only members of the Allied forces sent overseas without condoms which led to more widespread STDs among U.S. troops. In 1932, Sanger arranged for a shipment of diaphragms to be mailed from Japan to a sympathetic doctor in New York City. When U.S. customs confiscated the package as illegal contraceptive devices, Sanger helped file a lawsuit. In 1936, a federal appeals court ruled in United States v. One Package of Japanese Pessaries that the federal government could not interfere with doctors providing contraception to their patients.
In 1965, the U.S. Supreme Court case Griswold v. Connecticut struck down one of the remaining contraception Comstock laws in Connecticut and Massachusetts. However, Griswold only applied to marital relationships. Eisenstadt v. Baird (1972) extended its holding to unmarried persons as well.