The Supreme Court struck down bans on contraceptives for married couples, recognizing a constitutional right to marital privacy.
On June 7, 1965, the United States Supreme Court issued its decision in Griswold v. Connecticut, striking down a Connecticut law that criminalized the use of contraceptives, even by married couples. The Court held that the law violated a constitutional "right to privacy" implicit in the Bill of Rights, marking the first time the Supreme Court explicitly recognized such a right in the context of marital and reproductive decisions.
The case had been brought by Estelle Griswold, executive director of the Planned Parenthood League of Connecticut—an organization tracing its institutional lineage directly to Margaret Sanger's pioneering birth control clinics and advocacy. The decision built upon nearly five decades of legal and social groundwork that Sanger had laid, beginning with her 1916 Brownsville clinic and continuing through the 1936 One Package decision.
Justice William O. Douglas's majority opinion famously described various constitutional guarantees as creating "penumbras" and "emanations" that together established a right to privacy, a legal theory that would later underpin other landmark decisions, including Roe v. Wade in 1973. For Sanger, who died just three months after this ruling at age 86, the decision represented a historic vindication of her life's work—transforming birth control from a criminal act subject to arrest and prosecution into a constitutionally protected right for married couples, closing the legal chapter on the Comstock-era restrictions she had spent her life fighting.