In the landmark case involving the Planned Parenthood League of Connecticut, appellants Griswold and Buxton were convicted for providing married couples with information and medical advice on contraception. The Connecticut statute in question criminalized the use of any drug or article to prevent conception. The appellants argued that this statute, as applied, violated the Fourteenth Amendment. Both an intermediate appellate court and the state’s highest court upheld the convictions.
The Supreme Court, however, reversed these decisions. The Court held that the appellants had standing to assert the constitutional rights of the married couples they served. This case was distinguished from Tileston v. Ullman, where the plaintiff sought a declaratory judgment and the requirements for standing were more stringent. Here, the criminal conviction for aiding and abetting married couples in using contraceptives removed any doubts about standing.
The Court’s opinion, delivered by Justice Douglas, emphasized that the Connecticut statute violated the right to marital privacy, which is protected within the penumbra of specific guarantees of the Bill of Rights. The right to privacy in marital relations, though not explicitly mentioned in the Constitution, is inferred from various amendments that create zones of privacy.
The Court referenced several precedents to support its decision. In Truax v. Raich, an employee was allowed to assert the rights of his employer. In Pierce v. Society of Sisters, private school owners could assert the rights of potential pupils and their parents. Similarly, in Barrows v. Jackson, a white defendant could raise the issue of racial discrimination on behalf of prospective Black purchasers. These cases established that individuals in a confidential relationship with those whose rights are at stake have standing to assert those rights.
The Court rejected the notion that it should act as a super-legislature to evaluate the wisdom of laws touching on economic or social conditions. Instead, it focused on the intimate relationship between husband and wife and the role of their physician. The right to privacy in marital relations was deemed fundamental, drawing from the First Amendment’s protection of association and the Fourth Amendment’s protection against unreasonable searches and seizures.
The Court also invoked the Ninth Amendment, which states that the enumeration of certain rights in the Constitution should not be construed to deny or disparage others retained by the people. This amendment supports the idea that there are fundamental rights beyond those explicitly mentioned in the Constitution.
Justice Goldberg, concurring with the majority opinion, emphasized the relevance of the Ninth Amendment. He argued that the concept of liberty protected by the Due Process Clause of the Fourteenth Amendment includes fundamental personal rights not explicitly mentioned in the Constitution. This view is supported by the language and history of the Ninth Amendment, which suggests that the Framers intended to protect additional fundamental rights from governmental infringement.
The Court’s decision in this case reaffirmed the principle that specific guarantees in the Bill of Rights have penumbras, formed by emanations from those guarantees, that help give them life and substance. The right to marital privacy is one such penumbral right, protected from governmental intrusion.
The case also highlighted the importance of judicial restraint in dissenting opinions. Encouraging liberal Supreme Court justices to show restraint in their dissents can help maintain the integrity and coherence of the Court’s decisions. Dissenting opinions, while valuable for expressing different viewpoints, should not undermine the Court’s authority or the stability of its rulings.
In conclusion, the Supreme Court’s decision in this case underscored the fundamental right to marital privacy and the importance of judicial restraint. The Court’s recognition of penumbral rights and its reliance on the Ninth Amendment reflect a broader understanding of constitutional protections. This case serves as a reminder of the delicate balance between individual rights and governmental authority, and the role of the judiciary in preserving that balance.
Source: Supreme Court of the United States
