Griswold v. Connecticut is a Landmark Supreme Court case that establishes the right to privacy under the United States Constitution.

Griswold v. Connecticut: The Landmark Privacy Case

Griswold v. Connecticut (1965) is a landmark Supreme Court case that significantly impacted privacy rights in the United States. This case involved the constitutionality of a Connecticut law that prohibited the use of contraceptives. The Court’s ruling laid the groundwork for the right to privacy, shaping future legal interpretations and protections.

Background and Legal Challenge

In Griswold v. Connecticut, 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 for providing contraceptive advice to married couples. They challenged the law, arguing it violated the constitutional rights of married couples to privacy in their marital relations.

The Supreme Court Decision

The Supreme Court, in a 7-2 decision, ruled in favor of Griswold and Buxton, striking down the Connecticut law as unconstitutional. Justice William O. Douglas delivered the majority opinion, which was a pivotal moment for privacy rights.

The Right to Privacy and the Bill of Rights

Justice Douglas’s opinion emphasized that the right to privacy is implied by several amendments in the Bill of Rights. Although the Constitution does not explicitly mention “privacy,” the Court found that the First, Third, Fourth, Fifth, and Ninth Amendments create “zones of privacy.”

  1. First Amendment: Protects freedom of speech and association.
  2. Third Amendment: Prohibits the quartering of soldiers in private homes without consent.
  3. Fourth Amendment: Protects against unreasonable searches and seizures.
  4. Fifth Amendment: Ensures due process and protects against self-incrimination.
  5. Ninth Amendment: States that the enumeration of certain rights in the Constitution does not deny others retained by the people.

Concurrences and Dissents

Justices Arthur Goldberg, John Harlan II, and Byron White wrote concurring opinions. Justice Goldberg emphasized the Ninth Amendment’s role in protecting unenumerated rights. Justice Harlan and Justice White focused on the Fourteenth Amendment’s Due Process Clause.

Justices Hugo Black and Potter Stewart dissented. Justice Black argued that the right to privacy is not explicitly mentioned in the Constitution. Justice Stewart called the Connecticut law “uncommonly silly” but maintained it was not the Court’s role to strike it down.

Impact on Future Cases

Griswold v. Connecticut set a precedent for the right to privacy, influencing several critical cases:

  1. Roe v. Wade (1973): Extended privacy rights to a woman’s decision to have an abortion.
  2. Lawrence v. Texas (2003): Invalidated laws criminalizing private, consensual sexual conduct.
  3. Obergefell v. Hodges (2015): Legalized same-sex marriage nationwide, recognizing privacy in personal choices.

Constitutional Philosophies and Privacy

Justices apply different constitutional philosophies when interpreting privacy rights:

  1. Textualism: Focuses on the Constitution’s text. Justice Antonin Scalia was a prominent textualist, often opposing judicially inferred privacy rights.
  2. Originalism: Interprets the Constitution based on its original understanding. Justice Clarence Thomas supports this approach, often dissenting from decisions expanding privacy rights.
  3. Living Constitutionalism: Views the Constitution as evolving with societal changes. Justice William Brennan supported expanding privacy rights to adapt to modern realities.
  4. Pragmatism: Balances individual rights with societal interests. Justice Stephen Breyer’s pragmatic approach supports privacy rights when they benefit society.


Griswold v. Connecticut remains a cornerstone of privacy rights in American constitutional law. By recognizing a right to privacy implied by the Bill of Rights, the Supreme Court set a lasting precedent. This case continues to influence legal interpretations and protect individual freedoms. Understanding the principles and philosophies behind Griswold v. Connecticut is crucial for appreciating the ongoing evolution of privacy rights.


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