Much of the modern focus on the protection of privacy rights began with the case of Griswold v. Connecticut (1965), which involved a challenge of a criminal law that proscribed the use of contraceptives, even in private. According to the lead opinion written by Justice William Douglas, even though the Constitution was silent about the right to privacy, the Constitution nevertheless contained a “penumbra” of rights within the Bill of Rights that included the right to privacy. Since the criminal law in this case infringed upon the privacy rights of those who wished to use contraceptives, the Court ruled that it violated the Due Process Clause of the Fourteenth Amendment. Although other justices disagreed with the un-derlying rationale for recognizing privacy rights, the decision led to the recognition other fundamental rights in later cases.
