"Justice William Brennan also pushed marital privacy as the basis for the decision. In fact, Griswold turned into a martial privacy opinion because of Brennan. Though Douglas wrote the majority opinion, Brennan played a significant role behind the scenes, as his biographers, Seth Sterna and Stephen Wermiel, make clear: “There was no better example of the silent hand of Brennan shaping an opinion during this period than the case of Griswold v. Connecticut. . . . “ As soon as Brennan got Douglas’s first draft, he sent along a three-page letter on April 24, 1965, drafted by his clerk, suggesting a major shift from basing the decision on “the right of association . . . in the First Amendment context” to “the privacy of married couples.” Douglas “largely adopted Brennan’s approach.”"