According to a new report released by the Guttmacher Institute, the abortion rate is at its lowest point since the Supreme Court holding in Roe v. Wade, 41 years ago.

One in 3 women will have an abortion in her lifetime. Women of color are often wrongly stigmatized by abortion opponents for both having too many abortions and raising too many children in single-parent households.

In 1992, in a related case Planned Parenthood v. Casey, the Court affirmed the ruling in Roe, but held that states could restrict abortion access as long as there was no “undue burden.”  According to the joint opinion written by Justice Sandra Day O’Connor, “A finding of an undue burden is a shorthand for the conclusion that a state regulation has the purpose or effect of placing a substantial obstacle in the path of a woman seeking an abortion of a nonviable fetus.”

The issue turns on what courts consider to be an undue burden on a woman’s right to choose.  For example, a 24-hour waiting period is allowed but spousal notification is not because a policy requiring women to get their husbands’ approval before a medical procedure was a bridge too far for the Court.

And beyond the Court, Congress has also restricted abortion access further since Roe, passing the Hyde Amendment in 1976, which took away federal Medicaid coverage that helped low-income women pay for abortion procedures.  Despite the right to choose being the law of the land, since Roe abortion access has been under a constant legislative assault, particularly in the past 3 years since Republicans took over state houses and state legislatures all across the country in the 2010 midterm elections.

Some abortion opponents may argue that the decline in the number of abortions is good news and a result of their strategy to eliminate the right to choose by making it impossible for a woman who needs to terminate a pregnancy to obtain an abortion. In reality, a major factor in the decline in the abortion rate is increased access to contraception.  Lori Adelman, Executive Director of Partnerships and Outreach for told theGrio, “[T]he [current abortion] rate is more reflective of pro-choice, positive efforts to expand access to voluntary contraception and safe abortion  than it is of any “pro-life victory” though [some abortion opponents] are trying to frame it that way.”

Another factor in the decrease in the abortion rate is the lack of access.  Writer and activist Eesha Pandit told theGrio this argument misinterprets the data in the Guttmacher report, “I worry that this decline will be read as a decrease in demand or need for abortion access. In fact, I think the decline is likely related to the fact that almost 50 abortion clinics have closed since 2008, and more are closing every month.”

Pandit says, “[T]his decreasing access has the greatest impact on low-income people and marginalized communities, like women of color, immigrant and undocumented women, rural populations, and queer and trans communities, who are the most vulnerable in the face of restrictions and clinic closings.”

Many abortion restrictions block access by making abortions too expensive for low-income women.  In the pre-Roe world, there were not fewer women getting abortions, like many abortion opponents argue; middle-class women were able to have the procedure done at their private physicians and lower-income women were forced to seek out cheap and unsafe methods, which cost many women their lives.

Burdensome TRAP laws — laws that impose unfair regulations on clinics that perform abortions — are forcing clinics to shut their doors and a woman who can afford the procedure may still be forced to travel hundreds of miles to have the procedure done.  Low-income women lack access to contraception which would prevent unintended pregnancies and also have decreased access to safe abortion procedures when an unintended pregnancy occurs. Limiting  access to basic reproductive health care and contraception means that low-income women have even less control over their own lives, leaving many in an endless cycle of poverty and hardship.

“Unintended pregnancy and abortion are still more common among low-income women than among women with higher incomes. Poor women still have a hard time accessing contraception, particularly the most effective methods, and so we as a reproductive justice community still have more work to do,” says Adelman.

Follow Zerlina Maxwell on Twitter at @ZerlinaMaxwell.