IRAC Summary: Griswold v. Connecticut (1965)
Issue: 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?
Rule: The specific guarantees in the Bill of Rights have penumbras, formed by emanations from those guarantees that help give them life and substance. Various guarantees create zones of privacy.
Application: The use of contraceptives and a couple’s decision in relation to family planning fall within the zone of privacy created by several fundamental constitutional guarantees. Connecticut’s statute criminalizing the use of contraceptives and the aiding and counseling of their use by married couples is found to violate the right to marital privacy.
Conclusion: The Connecticut statute conflicts with the exercise of this right and is therefore null and void.
Detailed IRAC Outline: Griswold v. Connecticut (1965)
I. Issue
A. The primary legal issue in Griswold v. Connecticut is whether the Constitution guarantees a right to privacy that would protect a married couple’s decision to use contraceptives from state interference.
II. Rule
A. The Fourth Amendment creates a right to privacy against governmental intrusion.
B. The Fifth Amendment also creates a privacy right through its self-incrimination clause.
C. The Ninth Amendment provides that the enumeration of certain rights in the Constitution shall not be construed to deny or disparage other rights retained by the people.
D. The Fourteenth Amendment’s concept of personal liberty and restrictions upon state action includes a right to privacy.
III. Application
A. Factual Background
1. The appellants, Griswold and Buxton, were charged with giving married persons information and medical advice on how to prevent conception and, following examination, prescribing a contraceptive device or material for the wife’s use.
2. They were convicted under a Connecticut statute that criminalized the provision of counseling, and other medical treatment, to married persons for purposes of preventing conception.
B. Lower Court Decisions
1. The Supreme Court of Errors of Connecticut upheld the conviction, leading to the appeal to the U.S. Supreme Court.
C. Supreme Court’s Analysis
1. The Court recognized that while the right to privacy is not explicitly stated in the Constitution, various amendments create “zones of privacy.”
a. The First Amendment has a penumbra where privacy is protected.
b. The Third Amendment’s prohibition against the quartering of soldiers in any house in a time of peace without the consent of the owner is another facet of privacy.
c. The Fourth Amendment explicitly affirms the “right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures.”
d. The Fifth Amendment’s self-incrimination clause enables the establishment of a zone of privacy.
e. The Ninth Amendment states that the enumeration of certain rights in the Constitution shall not be construed to deny others retained by the people, indicating that other fundamental personal rights should not be denied.
2. The Court combined these Amendments to find a right to privacy in marital relations.
3. The Connecticut statute was found to violate this right as it pertains to marital privacy.
IV. Conclusion
A. The U.S. Supreme Court concluded that the Connecticut statute was unconstitutional as it violated the right to marital privacy.
B. The conviction of Griswold and Buxton was reversed.
C. The decision recognized that while the Constitution does not explicitly protect a general right to privacy, the various guarantees within the Bill of Rights create zones of privacy that establish a right to privacy in marital relations.