"Before considering abortion, the Justices had faced the issue of contraception. They eliminated state restrictions on contraceptives in two major cases in 1965 and 1972, an action that provoked little public opposition in the midst of the sexual revolution. The ease with which they were able to eliminate those laws likely gave some of the Justices a sense that the abortion laws were simply another set of laws that could be eliminated as an “invasion of privacy.” They saw contraception and abortion laws as one and the same intrusion on “privacy.” The Justices first seriously addressed the issue of contraception in 1961 in a case called Poe v. Ullman, but in a very limited way. The Connecticut statute in Poe was unique, the only one of its kind in the country to “criminally prohibit” the marital use of contraception. Although a majority of the Justices dismissed the Poe case-Justice Brennan complained about “this skimpy record”-two influential dissents by Justices William O. Douglas (a “liberal”) and John Harlan (a “conservative”) kept the issue alive. Both dissents emphasized marital privacy as the reason for striking the Connecticut law. Harlan made clear in Poe that “[t]he right to privacy most manifestly is not an absolute. Thus, I would not suggest that adultery, homosexuality, fornication and incest are immune from criminal enquiry, however privately practiced. So much has been explicitly recognized in acknowledging the State’s rightful concern for its people’s moral welfare.” The same Connecticut statute came back to the Court in 1965 in a similar test case, then called Griswold v. Connecticut. The Justices struck down the Connecticut criminal prohibition on the marital use of contraception and announced, for the first time, a general constitutional right of privacy. Griswold quickly became the Supreme Court precedent that spurred the litigation campaign against state abortion statutes, led in large part by Attorney Roy Lucas, who authored one of the first major law review articles attacking state abortion laws on constitutional grounds in 1969."