  Another strong critic of privacy is Robert Bork (1990), whose criticism is aimed at the constitutional right to privacy established by the Supreme Court in 1965. Bork views the Griswold v. Connecticut decision as an attempt by the Supreme Court to take a side on a social and cultural issue, and as an example of bad constitutional law. Bork’s attack is focused on Justice William O.  Douglas and his majority opinion in Griswold. Bork’s major point is that Douglas did not derive the right to privacy from some pre-existing right or from natural law, but merely created a new right to privacy with no foundation in the Constitution or Bill of Rights.  Bork is correct that the word “privacy” never appears in those documents. Douglas had argued, however, that the right to privacy could be seen to be based on guarantees from the First, Third, Fourth, Fifth, and Ninth Amendments. Taken together, the protections afforded by these Amendments showed that a basic zone of privacy was protected for citizens, and that it covered their ability to make personal decisions about their home and family life. In contrast, Bork argues i) that none of the Amendments cited covered the case before the Court, ii) that the Supreme Court never articulated or clarified what the right to privacy was or how far it extended, and he charges iii) that the privacy right merely protected what a majority of justices personally wanted it to cover. In sum, he accuses Douglas and the Court majority of inventing a new right, and thus overstepping their bounds as judges by making new law, not interpreting the law. Bork’s views continue to be defended by others, in politics and in the popular press.