Recent Supreme Court decisions, such as Whole Woman’s Health v. Hellerstedt, 136 S. Ct. 2292 (2016) and June Medical Services, LLC v. Russo, 140 S. Ct. 2103 (2020), and the COVID-19 pandemic have brough to light deep racial inequities in healthcare, especially as it relates to reproductive rights. However, court action alone will not be sufficient to achieve reproductive justice. The reproductive justice framework focuses on three tenets: (1) the right not to have a child, (2) the right to have a child, and (3) the right to parent one’s child safely. Viewing COVID-19 through a reproductive justice lense reveals how facially natural laws and policies, relating to these tenants, disproportionately harm women of color. However, courts are unwilling and, in some cases, unable to address the populations most harmed by their decisions. Instead, legislative action and meaningful participation by communities of color to develop a comprehensive health justice system is needed to address and support reproductive justice. The pandemic has exacerbated many of these reproductive justice issues. This Article surveys some of the most salient issues.