Griswold v. Connecticut 1. The background information: Griswold v. Connecticut involved a Connecticut law prohibiting the use of "any drug, medicinal article or instrument for the purpose of preventing conception." Although the law was passed in 1879, it was rarely enforced. A few attempts had been made to change the law such as Tileston v. Ullman (1943) Poe v. Ullman (1961). Doctors and patients challenged the statute on the grounds that a ban on contraception could, in certain situations, threaten the lives and well‐being of patients. However, the Supreme Court voted to dismiss both appeals. Shortly after the Poe decision was handed down, Estelle Griswold and Dr. C. Lee Buxton opened a birth control clinic in New Haven, Connecticut, to test the contraception law once again. Shortly after the clinic was opened, Griswold and Buxton were arrested, tried, found guilty, and fined $100 each. The conviction was upheld by the Appellate Division of the Circuit Court, and by the Connecticut Supreme Court of Errors. Griswold then appealed her conviction to the Supreme Court of the United States. 2. What the Supreme Court decided: Griswold v. Connecticut (1965) was a landmark case in which the Supreme Court of the United States ruled that the Constitution protected a right to privacy. Although the Bill of Rights does not explicitly mention "privacy", the argument of the Fourteenth Amendment’s due process clause and the Ninth Amendment were used to uphold the issue of protecting privacy. 3. The Implications: By a vote of 7‐2, the Supreme Court invalidated the law on the grounds that it violated the "right to marital privacy". The Supreme Court overturned Griswold's conviction and invalidated the Connecticut law. 4. It was important because: Since Griswold, the Supreme Court has cited the right to privacy in several rulings protecting access to sexual healthcare, most notably in Roe v. Wade, 410 U.S. 113 (1973). The Supreme Court ruled that a woman's choice to have an abortion was protected as a private decision between her and her doctor. Eisenstadt v. Baird (1972) extended its holding to unmarried couples, whereas the "right of privacy" in Griswold only applied to marital relationships. For the most part, the Court has made these later rulings on the basis of Justice Harlan's substantive due process rationale. The Griswold line of cases remains controversial, and has drawn accusations of "judicial activism".