The wayward child of the Bill of Rights. The Ninth Amendment saw very little judicial action until the landmark case of Griswold v. Connecticut, in which Justice Goldberg found that a generalized right to privacy could be grounded in this Amendment. (Current jurisprudence instead grounds the right to privacy in the Fourteenth Amendment's Due Process Clause.)

See also: penumbras and emanations, doctrine of enumerated rights, doctrine of preferred freedoms.

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