The Right to Privacy
In 1961, Estelle
Griswold and C. Lee Buxton, directors of a Planned Parenthood
Center, operated a clinic in New Haven to provide contraceptive
counseling and materials to married couples. They were arrested, as
accessories, for violating a state statute which made it a crime to
use devices or materials to prevent conception. After a trial, they
were found guilty as charged.
On appeal, both the
Appellate Division of the Circuit Court and the Connecticut Supreme
the judgments of conviction. The Connecticut Supreme Court concluded
that the conviction of Griswold and Buxton was not an invasion of
constitutional rights. Griswold and Buxton then took their case to
the United States Supreme Court.
In 1965, the United
States Supreme Court issued its landmark decision in Griswold v.
Connecticut, ruling that a married couple has a right of privacy
that cannot be infringed upon by a state law making it a crime to
use contraceptives. While the right of privacy is not specifically
guaranteed by the Constitution, the Griswold Court reasoned
that it emanates from certain guarantees in the Bill of Rights.
Griswold then paved the way for the Supreme Court’s historic
ruling in the 1973 case of Roe v. Wade. In Roe v. Wade,
the Supreme Court went on to hold that the right of privacy
encompasses a woman’s decision whether or not to terminate her
pregnancy. Griswold v. Connecticut served as an important
precedent in the Roe v. Wade decision.
See: State v.
Griswold, 151 Conn. 544 (1964)
Connecticut, 381 U.S. 479 (1965)
of Connecticut Legal History