This is one of the reasons I argue that forcing women to carry and bear children is involuntary servitude prohibited by the Thirteenth Amendment. The states who banned abortion also allowed and defended slavery. Forcing Black women to "breed" was an essential element of slavery, and abortion was one of the most common forms of resistance to it. Thus, prohibiting women from controlling their own bodies is a form “of compulsory labor akin to African slavery which in practical operation would tend to produce like undesirable results” which the Thirteenth Amendment was meant to address. Butler v. Perry, 240 U.S. 328, 332 (1916).