programs into block grants, thereby losing its national identity and character (and most of its funding). Nevertheless, it can now be seen, at least in retrospect, that under the apparent early consensus about family planning, there lurked a number of either unanticipated or unresolved issues that were to fester over a period of years and that are still, in part, unresolved.

The first unresolved issue is that the term family planning itself lacked and, to a lesser extent, still lacks a clear, commonly agreed on definition. As representatives of the Roman Catholic Church stated repeatedly during the congressional hearings that preceded the passage of Title X, the postponement of childbearing, the spacing of children, and the limitation of family size—what most people viewed as "family planning"—could be achieved in many ways: by periodic sexual abstinence (the only method approved by the Roman Catholic Church), by contraception, by contraceptive sterilization, by abortion, or by all four means of fertility regulation at different times or under different circumstances in anyone's life.

At the time, the fact that there were numerous ways to achieve one's desired family size may have appeared irrelevant to Congress: in the mid- or late 1960s, abortion was illegal in nearly all states and the use of contraceptive sterilization among the general population was low. The Title X legislation included "comprehensive, voluntary" family planning services, but without specification. It did contain a provision, adopted at the request of the U.S. Catholic Conference, prohibiting the use of Title X funds "in programs where abortion is a method of family planning." The Conference Report that accompanied the legislation further specified that the funds could be used "only to support preventive family planning services, population research, infertility services, and other related medical, informational, and educational activities." Thus, although the prohibition on the use of family planning funds for abortion was clear, the inclusion of contraceptive sterilization could only be inferred by a careful interpretation of the phrasing "preventive family planning." The only unambiguously endorsed means of family planning (beyond periodic abstinence) was contraception, as defined and understood at the time, but this was no small achievement given a century or more of religious and public controversy and the continuing opposition of some religious organizations.

Historical Background

Until the middle of the twentieth century, all religious denominations had condemned contraception as immoral. Largely because of the crusading activity of Anthony Comstock, the U.S. Congress in 1873 enacted a statute prohibiting the shipping of contraceptives (and of information about contraception) through the mail on the grounds of obscenity. Numerous states followed suit, passing

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