 The abortion issue also raises questions about how law should deal with issues of deep moral disagreement within society. In the United States, the protection of women’s reproductive freedom from restriction by government was initially based on the right to privacy and is now understood in terms of liberty. First applied to reproduction in the 1965 case of  Griswold v. Connecticut  (381 US 479 (1965)), the constitutional right to privacy was understood to protect individuals from state interference with certain decisions affecting their private lives, particularly decisions about marriage, family, sexual intimacy, and procreation. Griswold was jurisprudentially controversial because the right to privacy is not explicitly stated in the Constitution. Feminists have argued that originalist approaches to constitutional interpretation that would restrict constitutional meaning to the understandings in place at the time constitutional provisions were adopted are jurisprudentially problematic in their entrenchment of the norms of the patriarchy of the day (e.g. Case 2014) More recent decisions about abortion rights have been framed in terms of fundamental liberties that may not be unduly burdened (e.g.,  Planned Parenthood of Southeastern Pennsylvania v. Casey  (505 U.S. 833 (1992))).