Instead of trying to justify the right to marital privacy under substantive due process, the Court said that the marital privacy right was implied by the specific provisions of the Bill of Rights, such as those in the First, Third, Fourth, and Fifth Amendments. It referenced earlier cases where the Court had found personal liberties that were constitutionally protected despite not being specifically enumerated in the Constitution, such as the constitutional right to parental control over childrearing found in the early 20th century cases "Meyer v. Nebraska" and "Pierce v. Society of Sisters". The Court viewed marital privacy right's implicit nature to be similar, and in a now well-known line Douglas used the metaphor of shined light and its shadows to describe it.