Psychologists Grapple with Limits to Reproductive Justice in the Wake of Dobbs Ruling

In the wake of the Dobbs v. Jackson ruling, psychologists push for a reproductive justice framework that challenges systemic issues.


In light of the recent overturning of Roe v. Wade, the Journal of Social Issues made their Virtual Series Issue open access, providing an overview of three decades of research surrounding abortion. The author, Kevin Carriere of Washington and Jefferson College, approached the issue from a reproductive justice framework, highlighting the deeply rooted systemic problems that seek to limit reproductive freedom and interrogating key concepts cited in the majority opinion, including reliance interests and safe haven laws.

The right to abortion was described in Planned Parenthood v Casey, 1992 as “the personal freedom to make intimate and personal choices that are central to personal dignity and autonomy.” However, in Dobbs v. Jackson, 2022, the majority opinion ruled this right was not “absolute. On that historic day, Roe v. Wade was overturned after 50 years. The author argues that framing reproduction as an individual choice itself serves to distract from broader systemic issues, writing:

“The freedom to make choices itself is not a deeply rooted freedom…and such a belief is part of a neoliberal culture that must reckon with structural deficits in order to make true social change.”

Some structural deficits include the access, quality, and affordability of reproductive decision-making that is often only granted to a privileged few.

In the majority opinion, Supreme Court Justice Alito stated, “a right to abortion is not deeply rooted in the Nation’s history and traditions,” but failed to mention this is a history built on slavery, indigenous genocide, forced internment, and the oppression of women. This rationale opens the door for the court to target not only abortion rights but contraception, gay marriage, desegregation, and interracial marriage.

The majority opinion noted that in order to determine the legality of abortion, it needs to be shown that women have had what is referred to as reliance interest, which entails “reliance on the availability of abortion in the event that contraception should fail and the ability of women to participate equally in the economic and social life of the Nation has been facilitated by their ability to control their reproductive lives” (Dobbs v. Jackson, 2022, p. 60). The majority then opined that such reliance is “hard for anyone, including the court” to assess the effect of the abortion right on society and in particular the lives of women. This statement does not consider the glaring evidence about how abortion rights affect women and people with a uterus.

Next, the majority opinion cited “safe haven laws,” which generally “allow women to drop off babies anonymously, and that a woman who puts her newborn up for adoption today has little reason to fear that the baby will not find a suitable home” (Dobbs v. Jackson, 2022, p.34). Again, this statement ignores ample evidence on the US adoption system and how it harms children and birth parents, including evidence of long-term psychiatric difficulties for adoptees. Further, research shows that orphanages have staffing shortages, low wages, little training for caregivers, and a lack of psychological investment in children. As a result, children in these settings often lag in physiological, psychological, cognitive, and biological development.

Lastly, the author highlights the problems with focusing on adoption as it assumes a pregnancy is devoid of problems and ignores the physical, psychological, and emotional trials that exist and permeate through pregnancy, as well as the social and economic burdens that arise from pregnancy through birth. For example, the focus on adoption discounts families that want to have a child but must face the difficult medical decision to abort due to complications for the mother or fetus.

In closing, the author directs attention to psychologist Debra Mollen’s review of the research on the myths of abortions, the myths of the benefits of parenting, and the downstream consequences for societies that push too heavily on a “pronatalist viewpoint.” Finally, the author encourages psychologists and medical professionals to rely on these recommendations “now more than ever” as an increasing number of individuals seeking aid, counseling, and assistance regarding reproductive decisions is predicted to rise as they navigate a climate that has turned its back on progress.




Carrier, K.R. (2022). Deeply rooted in the patriarchy: The consequences and burden of overruling Roe. Virtual Series Issue. Journal of Social Issues. (Link)

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Madison Natarajan, PhD candidate
Madison is a doctoral candidate in the Counseling Psychology PhD program at the University of Massachusetts Boston. She is currently completing her pre doctoral internship at the Massachusetts Mental Health Center/Harvard Medical School working in psychosis interventions across the lifespan. Madison primarily considers herself an identity researcher, assessing the ways in which dominant cultural norms shape aspects of racial and gender identity for minoritized individuals, with a specific focus on the intersection of evangelicalism and its relationship to Christian Nationalism. Madison has a family history that has been intertwined with psychiatric care, ranging from family members who were institutionalized to those practicing psychiatry, both in the US and India. Madison greatly values prioritizing the experiences of those with lived experience in her research and clinical work, and through her writing in MIA seeks to challenge the current structure of psychiatric care in the West and disseminate honest and empowering information to the community at large.


  1. Not sure what this has to do with psychiatric diagnosis and treatment? Certainly, restricted abortion rights will have an effect on women’s mental health. In my opinion, though, abortion itself can have an effect on women’s mental health. It’s a very complicated issue.

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  2. “Not sure what this has to do with psychiatric diagnosis and treatment?…It’s a very complicated issue.”

    No, it’s really not all that complicated. Especially when you consider that HALF of the U.S. population just had a fundamental human right (the control of reproductive rights and one’s own body) taken away by the mere stroke of a pen.

    Taken away by so-called “justices” who once again are trying to impose their “theology” on people’s “biology.” This is an example of patriarchy in one of its worst forms; not fundamentally all that different than what we criticize in those countries ruled by extreme forms of Muslim theology.

    I applaud Madison and MIA for publishing this important summary of author Kevin Carriere’s journal article on a reproductive justice framework.

    And this issue (just like racial oppression) has EVERYTHING to do with psychiatric diagnoses and the medical model. Both minorities and women in this society are more likely to become victims of all forms of psychiatric abuse than other segments of our society.

    AND this recent SCOTUS ruling will only ADD additional social and economic stressors to both women and minorities, especially those without the economic means to pursue appropriate medical care.

    One CANNOT really call themselves a feminist OR believe in equal rights for ALL human beings, unless they firmly uphold the fundamental right of a woman to have an abortion – ON DEMAND AND WITHOUT APOLOGY!


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  3. From a mental health standpoint the real concerns are the unintended consequences. Personally it’s none of my business what another person decides to do with their body. My concern is that legislating morality is itself is often an immoral act. Psychiatry has a checkered history largely because of its attempt to pathologize morality and much of it is rooted in the same religious movement responsible for the current abortion debate. Many of the solutions we need are not possible without legislative action and the mental health community must quit accepting condescending lip service and start demanding evidence based solutions.

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