Respect for those procedural constraints, as Barnett notes, is the price of using public as opposed to private institutions to achieve social goals.
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One may, however, take a more thoroughgoing natural rights approach to the Ninth Amendment. Bennett B. Patterson, for example, emphasizes its close connection with the Declaration of Independence, which does not state that rights and liberties are contrived by governments but rather are "inalienable" and are "endowed" by a "Creator.'' Jefferson carefully prefaced his list of the rights of life, liberty, and the pursuit of happiness by the words "among these," implying that such a list is not complete. Governments, he adds, are instituted "to secure these Rights."
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Patterson would see the Declaration of Independence as a legal as well as philosophic document and looks for the day when the courts will cite it as a legal authority for a doctrine that individual liberties are natural and inherent rather than deriving from the U.S. Constitution. The Constitution, says Patterson, echoing Jefferson, was never intended to be the creator but only the protector of these rights. 15
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This view understands the Ninth Amendment as opening the door to a wider range of rights, wider than the Constitution and, for Patterson, wider also than the Declaration of Independence. It recognizes a spectrum of individual rights more inclusive than those consistent with presently enumerated constitutional principles.
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Prior to 1965 the Supreme Court had never used the Ninth Amendment as a basis for a decision. Then, in Griswold v. Connecticut, which concerned the legality of making information about contraceptives available to married couples, the majority opinion, written by Justice Douglas, used the Ninth Amendment as support for the existence of a "penumbra" of privacy surrounding certain specific rights in the first eight amendments. 16 in a concurring opinion, Justice Goldberg elaborated on the language and history of the Ninth Amendment, which reveal "that the Framers of the Constitution believed that there are additional fundamental rights, protected from govern-
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