Griswold v. Connecticut was a pivotal Supreme Court case in 1965 that struck down a Connecticut law banning the use of contraceptives by married couples. The case involved Estelle Griswold, the executive director of the Planned Parenthood League of Connecticut, who was arrested for providing contraceptive advice and devices to married couples. The central issue before the Court was whether the Connecticut law violated the constitutional right to privacy.

The constitutional principle at the heart of the case was the right to privacy, which the Court determined to be implied by several amendments in the Bill of Rights, even though it is not explicitly stated in the Constitution. Justice William O. Douglas, writing for the majority, argued that the "right to privacy" could be inferred from the "penumbras" (or implied rights) created by various provisions in the Bill of Rights, including the First, Third, Fourth, Fifth, and Ninth Amendments. The Court concluded that the law banning contraceptives violated this implied right to privacy in the marital relationship.

The decision in Griswold was seen as judicial activism by many critics. They argued that the Court was overstepping its bounds by creating a right to privacy that was not explicitly mentioned in the Constitution. The critics believed that the Court was interpreting the Constitution in a way that went beyond the text and the original intent of the framers, thus engaging in judicial overreach. Rather than leaving such a significant social issue to the legislative process, the Court was seen as making a policy decision.

An alternative ruling based on judicial restraint could have involved the Court choosing not to recognize an implied constitutional right to privacy. Instead, the Court could have allowed the issue of contraceptive use to remain within the domain of state law, thereby deferring to the democratic process. This would have respected the principle of judicial restraint, where courts avoid making sweeping changes to law or policy unless there is clear, explicit constitutional support for such actions.

The impact of Griswold v. Connecticut was significant. It was a key decision in establishing the constitutional right to privacy, which later played a foundational role in other important rulings, such as Roe v. Wade (1973) and Lawrence v. Texas (2003). The decision expanded individual rights, particularly in the context of personal relationships and reproductive choices, and set a precedent for recognizing privacy rights in other areas of life. While Griswold did not immediately change state laws across the country, it paved the way for greater freedom in matters of contraception and sexual privacy. The case also marked a broader shift in the Court's approach to individual liberties, asserting a more expansive view of constitutional protections.