In 1973, the Supreme Court ruled in Roe v. Wade that a constitutional right to privacy exists, based on decades of precedent going back to 1891. The court specifically references the right to privacy as having roots in the First, Fourth, Fifth, Ninth and Fourteenth Amendments to the Constitution, as well as in the penumbras of the Bill of Rights. The court further enumerated that privacy rights were upheld in the areas of contraception, family relationships, child-rearing and education. In the Supreme Court opinion in Dobbs v. Jackson, No. 19-1392 (2022), recently reversing Roe, the privacy rights in these enumerated areas will suffer.