The Supreme Court has always protected enumerated rights and will, of course, continue to do so, following standards and guidelines it has established. This comment will confine itself to the protection of unenumerated rights. Initially, it will explore the doctrine used in the past to void laws violative of unenumerated rights-substantive due process. Then the ninth amendment will be suggested as a source of protected behavior, with John Stuart Mill's On Liberty being offered as a criterion for the determination of ninth amendment rights.
George E. Garvey, Note, Unenumerated Rights – Substantive Due Process, the Ninth Amendment and John Stuart Mill, 1971 WIS. L. REV. 992.