rson's body (Mason and Stephenson, 1987, 442).
The issue of privacy was raised in 1965 in Griswold v. Connecticut in which Connecticut's anticontraceptive statute, though it did not violate any express guarantees of the Bill of Rights, was found to violate the penumbral right of privacy, a right not expressly stated in the Constitution but found in the shadow, or penumbra, of other rights that are enumerated in the Constitution. Justice Douglas wrote in that case that "Specific guarantees of the Bill of rights have penumbras, formed by emanations from those guarantees that give them life and substance" (Mason and Stephenson, 1987, 442). Privacy was raised in Hardwick v. Bowers, a case in which a Georgia statute against homosexual conduct had been invoked. This law dated from 1816 and defined the crime of sodomy. There were many laws early in American history against "the detestable and abominable crime against nature," as sodomy was defined in common law. All the
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