The right of privacy recognized by the Warren Court in Griswold opened the door for the incorporation of other unspecifi ed rights into the Fourteenth Amendment. The notion that the Constitution protects rights implied but not enumerated in the fi rst eight amendments opened up all sorts of possibilities for civil libertarians. Previously, except for the restraints spelled out in the Constitution, the states had a relatively free hand to legislate with respect to the health, welfare, and morals of their citizens. Griswold for the fi rst time put limits on the power of government to regulate private behavior by recognizing that there are zones of personal privacy upon which government may not intrude. As these zones expanded in subsequent cases, the reach of government would be signifi cantly diminished.