In the early 1900s, abortions and birth control were widely available in the United States. The Comstock Act made it illegal to distribute information about reproductive health. In 1916, New York nurse Margaret Sanger opened the first American birth control clinic. She was prosecuted under the Comstock Act, but appealed her conviction and won a major legal victory for birth control. She went on to win more victories for contraceptives by publishing The Birth Control Review, establishing the American Birth Control League, and working with Gregory Pincus, a biologist, to develop the first oral contraceptive. Sanger’s Birth Control League would become Planned Parenthood, the largest supplier of reproductive health services in the United States. Sanger has come under criticism in recent years for her involvement in the eugenics movement.