The government has used reproductive control as a carceral tool for centuries, especially against women of color. While scholars anticipate the overturn of Roe v. Wade will exacerbate state surveillance and control over pregnancy, the current “pro-choice” rhetoric neglects the state’s history of policing reproduction through forced sterilization programs, fetal protection laws, and criminal prosecutions against pregnant persons and caregivers dependent on narcotics. Without a complete understanding of this history and the intersectionality of race, gender, socioeconomic status, disability, and crime, reproductive liberation is not possible. Thus, this Note aims to contribute to existing reproductive justice scholarship and advocacy efforts of women and gender-nonconforming people of color by contextualizing the overturn of Roe within the history of racial eugenics and reproductive punishment. In doing so, this Note uses the history of eugenics and state-sanctioned reproductive oppression to show that abortion is not “a tool of modern-day eugenics,” as conservatives inaccurately proclaim. Adopting a reproductive justice framework is necessary to realize true reproductive freedom.