Griswold v. Connecticut

Griswold v. Connecticut, Supreme Court, 1965

Facts of the Case

Estelle Griswold, the Executive Director of the Planned Parenthood League of Connecticut, and Dr. C. Lee Buxton, a physician and professor at Yale Medical School, were arrested and convicted for providing contraceptive advice and devices to married couples. Their actions violated a Connecticut law that prohibited the use and dissemination of contraceptives. Griswold and Buxton argued that the law violated the constitutional rights of marital privacy.

Constitutional Question

Does the Constitution protect the right of marital privacy against state restrictions on a couple’s ability to be counseled in the use of contraceptives?

Arguments

For Griswold and Buxton:

  • The Connecticut law infringes upon the fundamental right of marital privacy, which is protected by several provisions in the Bill of Rights.
  • The right to privacy in marital relations is inherent in the liberties guaranteed by the First, Third, Fourth, Fifth, and Ninth Amendments.
  • The state has no legitimate interest in regulating the private, consensual activities of married couples.

For the State of Connecticut:

  • The state has the authority to regulate the use of contraceptives in the interest of public morals and health.
  • The law is a legitimate exercise of the state’s police powers and does not violate any specific constitutional protections.
  • The Constitution does not explicitly guarantee a right to privacy, and therefore the law does not infringe upon any constitutional rights.

The Decision

The Supreme Court, in a 7-2 decision, ruled in favor of Griswold. Justice William O. Douglas, writing for the majority, held that the Connecticut law violated the right to marital privacy. The Court found that although the Constitution does not explicitly mention a right to privacy, several amendments create “penumbras,” or zones, that establish a right to privacy. These amendments include the First, Third, Fourth, and Ninth Amendments. The Court concluded that the Connecticut statute was unconstitutional because it infringed upon the protected zone of privacy in the marital relationship.

Significance

Griswold v. Connecticut is a landmark case that established the constitutional basis for the right to privacy, particularly in matters of marriage and family planning. This decision laid the groundwork for subsequent cases that expanded privacy rights, including Roe v. Wade, which extended the right to privacy to a woman’s decision to have an abortion. Griswold v. Connecticut highlighted the Court’s role in protecting individual liberties from state intrusion and underscored the importance of privacy in intimate and personal decisions. This case remains a pivotal precedent in the jurisprudence of privacy rights in the United States.