About This Case Study

Margaret Sanger — birth-control pioneer, founder of the organization that became Planned Parenthood, and an active participant in the American eugenics movement — has been one of the most contested figures in twentieth-century American reproductive politics. The contestation is not over whether Sanger held eugenic views; the documentary record is clear that she did, including her endorsement of Buck v. Bell and her speech to the Ku Klux Klan's women's auxiliary in 1926. The contestation is over how to read those views in relation to her work, what counts as evidence, and what the present-day descendants of her institutions owe to her legacy and to the communities her work touched.

This case study asks you to read three sources that take three different positions on Sanger's legacy: an archival assessment by the Margaret Sanger Papers Project (a scholarly project at New York University), Planned Parenthood's own defensive document "Opposition Claims About Margaret Sanger" (which was cited in Supreme Court briefing in Box v. Planned Parenthood), and Planned Parenthood's public-facing institutional history. Each source is doing different rhetorical work; each operates from a different position; and the three do not finally agree. The exercise's analytical move is not to pick a winner but to read the contestation itself — to see what each source contributes, where they converge, and where they talk past each other — and to ask what the disagreement reveals about how the legacy of eugenics is metabolized in the present.

Before You Begin

Pre-reading is required. Read each source closely enough to identify its central claims about Sanger:

• Margaret Sanger Papers Project. "Birth Control or Race Control? Sanger and the Negro Project." NYU, 2001. (sanger.hosting.nyu.edu)
• Planned Parenthood. "Opposition Claims About Margaret Sanger." 2016, updated April 2021. As cited in Supreme Court briefing in Box v. Planned Parenthood of Indiana and Kentucky, Inc., No. 18-483, October Term 2018. (supremecourt.gov, URLs Cited record)
• Planned Parenthood. "Our History." Planned Parenthood Federation of America. (plannedparenthood.org)

You should also have at hand your notes on Dorothy Roberts, Killing the Black Body, especially the chapter on Sanger and the Negro Project. Roberts's framework is the analytic instrument you will bring to the sources in the exercise's final phase.

While reading, keep these prompts in mind:

• What does this source say about the Negro Project specifically?
• What does this source acknowledge about Sanger's eugenic ties? What does it minimize, contextualize, or defend?
• Who is the source's audience, and what is it trying to do for that audience?

The Exercise

Phase 1: Reading the Sources on Their Own Terms (12–15 minutes)

Take each of the three sources in turn. For each, write a brief paragraph (three to five sentences) identifying its central claim about Sanger, its rhetorical posture, and the audience it appears to be addressing.

To start you off, here is one way of characterizing what each source is doing — read the sources first and decide whether you agree, sharpen, or revise:

• The Sanger Papers Project argues that Sanger's collaboration with Black community organizations in the Negro Project — including W. E. B. Du Bois, Mary McLeod Bethune, and Rev. Adam Clayton Powell — should be read as a genuine effort to extend reproductive-health services to Black women in the rural South, and that the conspiracy framing of the project as a covert program of racial extermination depends on misreading specific quotations (notably the 1939 letter remarking that "we do not want word to go out that we want to exterminate the Negro population"). The Project's posture is scholarly and archival; its audience is the public sphere of historical interpretation; its rhetorical work is defending an accurate reading of the record against political distortion.
• "Opposition Claims About Margaret Sanger" is Planned Parenthood's defensive document. It acknowledges that Sanger held eugenic views, endorsed Buck v. Bell, and supported sterilization of those deemed "feebleminded" — and explicitly denounces those positions. At the same time, the document defends Sanger against what it identifies as misattributions, distortions, and bad-faith readings. Its posture is institutionally defensive; its audience is Planned Parenthood's broader public, including donors, critics, and political opponents; its rhetorical work is acknowledging harm without surrendering Sanger as a founding figure.
• "Our History" is Planned Parenthood's present-day institutional self-narration. It frames the organization as the descendant of Sanger's 1916 Brownsville clinic and her subsequent activism while incorporating, with increasing explicitness over recent years, an acknowledgment of Sanger's racism and the organization's ongoing reckoning with it. (Planned Parenthood of Greater New York removed Sanger's name from its Manhattan health center in July 2020.) Its posture is institutional and forward-looking; its audience is current and prospective patients, supporters, and the public; its rhetorical work is positioning the organization in the present without disowning the past.

For groups: assign each member one source. Each member presents their characterization in two minutes. The full group should then briefly note where their characterizations agree and where they differ — disagreements about what a source is doing are evidence the source is operating in more than one register.

Phase 2: Where the Sources Converge, Diverge, and Talk Past Each Other (10–12 minutes)

Now read the three sources against one another. The contestation over Sanger is not a single argument with three positions; it is several different conversations happening at once. Identify, in your notes:

1. Convergences. Where do all three sources agree? (For example: all three acknowledge that Sanger held eugenic views and endorsed Buck v. Bell. The dispute is not over the existence of these views but over how to read them.)
2. Divergences. Where do the sources clearly disagree? (For example: the Sanger Papers Project tends to read the Negro Project as a genuine partnership with Black leaders; the Planned Parenthood documents, while not contradicting this, more clearly distance the institution from Sanger's eugenic associations as years pass.)
3. Talking past each other. Where are the sources doing different kinds of work that don't directly meet? (For example: the Sanger Papers Project is doing archival scholarship; "Opposition Claims" is doing defensive institutional advocacy; "Our History" is doing institutional self-positioning. These are not the same activity, even when they engage the same evidence.)

One feature worth noting in this constellation: the "Opposition Claims" document, written by Planned Parenthood to defend Sanger from misrepresentation, was cited by Justice Clarence Thomas in his concurrence in Box v. Planned Parenthood (OT 2018) — but for the opposite purpose. Thomas used Planned Parenthood's own acknowledgment of Sanger's eugenic views to argue that contemporary abortion access perpetuates a eugenic project. The same document, in different hands, became evidence for opposing political claims. What does this circulation reveal about how contested historical legacies are made and remade in present-day political life?

For groups: divide a sheet (or a shared document) into three columns — Converge, Diverge, Talk Past — and fill them in collaboratively for ten minutes.

Phase 3: What Is at Stake in the Contestation (5–10 minutes)

Step back from the textual work for a moment. Each of these sources is engaged in something more than describing Sanger — each is doing political and institutional work in the present.

Ask:

• What does the Sanger Papers Project gain by holding the archival record steady against simplification?
• What does Planned Parenthood gain — and what does it risk — by acknowledging Sanger's flaws while continuing to claim her as a founder?
• What did Justice Thomas gain by citing Planned Parenthood's own acknowledgments back to them?
• What might communities historically harmed by reproductive coercion gain or lose from each of these framings?

Choose one of these questions to develop in writing or discussion. The aim is not to assign motives in bad faith but to recognize that disputes over a contested legacy are also disputes over the legitimacy of present-day institutions, political positions, and reparative claims.

Phase 4: Returning to Roberts (5–7 minutes)

Dorothy Roberts argues in Killing the Black Body that twentieth-century American reproductive politics — from chattel slavery through Sanger's Negro Project and forward into Norplant, welfare-conditioned contraception, and sterilization in carceral settings — has operated as a continuous racial project that has conscripted Black women's bodies in service of changing demographic anxieties. Roberts's argument is not that Sanger personally orchestrated this trajectory but that her work was one moment in a much longer pattern.

Bringing Roberts back to the three sources, ask: which of the three sources comes closest to seeing what Roberts sees? Which falls shortest? Where does Roberts's framework do work that none of the three sources, individually, does?

Complete this thought in one or two sentences:

Reading Sanger through Roberts changes my reading of the three sources because __________. The source that comes closest to Roberts's framework is __________, because __________. The framework asks something of the historical record that none of the three sources, on its own, asks — namely __________.

Closing Reflection

In a few sentences, articulate where you have arrived. The aim is not to render a verdict on Sanger but to identify what you now think the contestation is about.

The contestation over Margaret Sanger's legacy is, at its core, a contestation about __________. Reading the three sources against each other has changed my sense of __________. The hardest thing to hold steady, after this exercise, is __________.

A Note on Modes

Solo mode. Work through the four phases in order. The Phase 1 characterizations and the Phase 2 three-column map are the central artifacts; keep them for reference when answering Question 1 (on Roberts and the Sanger case study) in the unit's Questions for Reflection.

Group mode (3–6 people). Designate a timekeeper. In Phase 1, divide the sources among members and reconvene to compare characterizations. Phase 2 works well as collaborative map-building on a shared document or whiteboard. Phases 3 and 4 work either as full-group discussion or as individual writing followed by brief sharing. The closing reflection can be a single shared sentence or a list of each member's variation — both are useful.

After the Case Study

• Return to Question 1 in the unit's Questions for Reflection, which asks you to characterize a specific decision or rhetorical move by Sanger or her successors as a racial project in Roberts's sense. The Phase 2 map and the Phase 4 synthesis supply most of the material for this answer.
• To extend the exercise, the Margaret Sanger Papers Project's larger online archive at New York University includes Sanger's correspondence, speeches, and editorials from The Birth Control Review. Working directly with primary sources lets you test the three secondary sources' readings against the record they each claim to interpret.
• For the contemporary dimension, the unit's OER reading by Panofsky and colleagues — "Confronting the 'Weaponization' of Genetics by Racists Online and Elsewhere" — examines how genetic science is being deployed in present-day racist projects. The Sanger contestation and the contemporary weaponization of genetics are not the same phenomenon, but reading them together reveals how the eugenic past is metabolized in present-day political and scientific debate.