To the ordinary layman, Griswold v. Connecticut seemed easy. But to the lawyer it was somewhat more difficult. The lawyer's problem with the case was that the issues did not readily fit into any existing legal pigeonhole. Actually, there were five possibilities. The case could have been dealt with under the equal protection clause, the first amendment, substantive due process, the right of privacy, or, in extremis, the ninth amendment. In order to strike down the statute under any of these doctrines, however, the Court would be forced to enter uncharted waters. Whatever course the Court took, its action was bound to be pregnant with possibilities crucial to the development of the law in a vital area of American life.
Thomas I. Emerson,
Nine Justices in Search of a Doctrine,
Mich. L. Rev.
Available at: https://repository.law.umich.edu/mlr/vol64/iss2/3