The fourth Amendment protects citizens from unreasonable searches and seizures. It does this by guaranteeing citizens due process of law and by applying the exclusionary rule, which makes evidence from illegal searches inadmissible. The Court found that when one takes the penumbras together, the Constitution creates a "zone of privacy." While the holding in Griswold found for a right to privacy, it was narrowly used to find a right to privacy for married couples, and only with regard to the right to purchase contraceptives. In privacy cases post-Griswold, the Supreme Court typically has chosen to rely upon Justice Harlan's concurrence rather than Justice Douglas's majority opinion. Eisenstadt v Baird (1971), Roe v. Wade (1972), and Lawrence v. Texas (2003) are three of the most prolific cases in which the Court extended the right to privacy. In each of these cases, the Court relied upon the Fourteenth Amendment, not penumbras.
