Court: U.S. Supreme Court
Judgment Date: 7 June 1965
Where Reported: 381 U.S. 479
Legal Issue in Griswold v Connecticut
The central legal issue in Griswold v Connecticut was whether a state law prohibiting the use of contraceptives violated the Constitution. The case specifically questioned if such a law infringed upon the right to marital privacy.
This legal challenge raised fundamental questions about the extent to which the government could intrude into the private lives of individuals, particularly concerning intimate and personal decisions within a marriage.
Material Facts in Griswold v Connecticut
In Griswold v Connecticut, the executive director of the Planned Parenthood League of Connecticut, Estelle Griswold, and its medical director were convicted as accessories for providing information, medical advice, and contraceptives to married couples.
The case arose from a Connecticut statute making it a crime to use any drug, medicinal article, or instrument for the purpose of preventing conception. The appellants were fined $100 each, challenging the statute as a violation of the Fourteenth Amendment.
Their case raised critical issues about the constitutional rights of married individuals and the legality of state laws regulating personal and private choices, particularly in the area of contraception and marital privacy​​​​.
Judgment in Griswold v Connecticut
The Supreme Court, in a landmark decision, declared the Connecticut statute unconstitutional. The Court held that the statute violated the right to marital privacy, which falls within the “penumbras” and “emanations” of several guarantees of the Bill of Rights.
The ruling emphasised that the Constitution’s protections extended to intimate choices made within the marital relationship, including the use of contraceptives.
The Court’s opinion, delivered by Justice Douglas, underscored that the right of privacy in marriage is a fundamental right protected by the Constitution. This decision effectively invalidated the Connecticut statute and set a precedent for protecting privacy rights in marital and intimate relationships​​​​.
The Reason for the Decision in Griswold v Connecticut
The Supreme Court’s decision was rooted in the concept of implied constitutional rights, particularly the right to privacy.
The Court reasoned that while the right to privacy was not explicitly stated in the Constitution, it was implied by the “penumbras,” or implied protections, and “emanations” from explicit guarantees in the Bill of Rights.
This legal theory posited that certain fundamental rights, including the right to marital privacy, are inherently protected by the Constitution, even if not explicitly mentioned.
The decision drew on previous cases that recognised rights not explicitly mentioned in the Constitution but deemed fundamental. This included the right of association, as protected in cases like NAACP v Alabama, where the Court had upheld the privacy of association against governmental intrusion.
The Court also cited cases like Schware v Board of Bar Examiners, which supported the right of association and expression beyond the explicit text of the First Amendment.
In articulating this framework, the Court established that the rights enumerated in the Bill of Rights had “penumbras,” or implied protections, that provided a basis for recognising a right to privacy.
This included references to the Third Amendment’s protection against the quartering of soldiers in homes, the Fourth Amendment’s protection against unreasonable searches and seizures, and the First Amendment’s protection of association and free expression.
The Court’s interpretation emphasised that constitutional protections extend to the private sphere, particularly within the sanctity of marriage.
The ruling in Griswold v Connecticut suggested that the government’s intrusion into this private sphere must be carefully scrutinised and that individual liberties in these intimate areas are paramount and deserving of protection.
Conclusion
Griswold v Connecticut is a seminal case in constitutional law, establishing the right to privacy, particularly in the context of marital relations.
The Court’s decision to strike down the Connecticut statute on contraceptives marked a fundamental shift in constitutional jurisprudence, recognising implied rights within the Constitution’s protections.
This case set the foundation for subsequent rulings on privacy rights and played a crucial role in shaping modern understandings of personal liberty, autonomy, and the limits of governmental power in regulating intimate and personal decisions.
