In Griswold, Justice Stewart skewered the majority for asserting that the Ninth Amendment of the US Constitution supported its decision to overturn the Connecticut contraception statute. He wrote, “The idea that a federal court could ever use the Ninth Amendment to annul a law passed by the elected representatives of the people of the State of Connecticut would have caused James Madison no little wonder.”

What does the Ninth Amendment say, and why would Justice Stewart say that President Madison, in particular, would be perplexed by its use to justify the majority’s opinion?