&gt; So IANAL, but didn&#x27;t Griswold v. Connecticut establish that some rights DO exist without being enumerated anywhere?<p>Not really,<p>&gt; Specifically, that the guarantees in the bill of rights have &quot;penumbras&quot; that imply other rights not explicitly stated in any text<p>No, the ideas of &quot;penumbras&quot; and &quot;emanations&quot; in Griswold are not nonenumerated rights; they are the full scope of the meaning of particular enumerated rights and products of the combination of those enumerated rights, not rights that exist independent of enumeration.