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6 - “Unenumerated” Fundamental Rights

Published online by Cambridge University Press:  05 May 2013

Richard H. Fallon, Jr
Affiliation:
Harvard University, Massachusetts
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Summary

“[L]iberty” is not a series of isolated points pricked out in terms of…freedom of speech, press, and religion…and so on. It is a rational continuum which, broadly speaking, includes a freedom from all substantial arbitrary impositions and purposeless restraints.

– Justice John Marshall Harlan

The Court is most vulnerable and comes nearest to illegitimacy when it deals with judge-made constitutional law having little or no cognizable roots in the language or design of the Constitution.

– Justice Byron White

AS THE SUPREME COURT NOTED IN THE FIRST SENTENCE of its opinion, the case of Skinner v. Oklahoma (1942) “touche[d] a sensitive and important area of human rights.” The state of Oklahoma sought to sterilize Jack T. Skinner against his will. In the state's view, Skinner was a “habitual criminal,” convicted three times of crimes involving “moral turpitude” – twice for “robbery,” once for stealing chickens. Oklahoma's “Habitual Criminal Sterilization Act” called for repeat offenders to be sterilized in order to stop people with manifest criminal tendencies from passing those tendencies to fut-ure generations.

Type
Chapter
Information
The Dynamic Constitution
An Introduction to American Constitutional Law and Practice
, pp. 191 - 224
Publisher: Cambridge University Press
Print publication year: 2013

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References

Poe v. Ullman, 367 U.S. 497, 543 (1961)
Bowers v. Hardwick, 478 U.S. 186, 194 (1986)
Lawrence v. Texas, 539 U.S. 558 (2003)
Dworkin, Ronald, “Unenumerated Rights: Whether and How Roe Should Be Overruled,” 59 University of Chicago Law Review381 (1992)CrossRefGoogle ScholarPubMed
Colegrove v. Green, 328 U.S. 549, 556 (1946)
Levinson, Sanford, “One Person, One Vote: A Mantra in Need of Meaning,” 80 North Carolina Law Review1269 (2002)Google Scholar
Thornburg v. Gingles, 478 U.S. 30 (1986)
Posner, Richard A., Breaking the Deadlock: The 2000 Election, the Constitution, and the Courts (Princeton, NJ: Princeton University Press, 2001)CrossRefGoogle Scholar
Northern Securities Co. v. United States, 193 U.S. 197, 400 (1904)
Choper, Jesse H., “Consequences of Supreme Court Decisions Upholding Individual Rights,” 83 Michigan Law Review 1, 185 (1984)CrossRefGoogle Scholar
Stenberg v. Carhart, 530 U.S. 914 (2000)
Lincoln, Abraham, Speeches and Writings, 1832–1858, (New York: Library of America, 1989), 460, 472–79Google Scholar
Loving v. Virginia, 388 U.S. 1 (1967)
Zablocki v. Redhail, 434 U.S. 374 (1978)
Jacobson v. Massachusetts, 197 U.S. 11 (1905)

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