Griswold v. Connecticut (1965 Privacy, SCOTUS)
Legal Issues
The Facts
Connecticut prohibited the use of contraceptives and the giving of contraceptive advice. Estelle Griswold, executive director of Planned Parenthood, was convicted for counseling married couples on contraceptive use. She challenged the law on constitutional grounds.
The Issue
Whether Connecticut's anti-contraception law violates the constitutional right to marital privacy
The Rules
Penumbras of the Bill of Rights — constitutional right to privacy
Due Process Clause liberty interest
First, Third, Fourth, Fifth, and Ninth Amendment penumbras
The Application
Connecticut's blanket prohibition on contraceptive use and advice intruded directly into the zone of marital privacy that the Court identified through the penumbral protections of the Bill of Rights. The prosecution of Griswold for counseling married couples on contraception exemplified the precise type of governmental intrusion into intimate, personal decisions that the newly articulated privacy right was designed to prevent. Because Connecticut offered no compelling state interest justifying such a sweeping restriction on marital choice, the Court found the law unconstitutional as applied to married couples' access to and knowledge of contraceptives.
The Conclusion
Court held 7-2 the law unconstitutional. Justice Douglas wrote for the majority; Justices Black and Stewart dissented. Foundational privacy rights precedent.
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