How have the Supreme Court interpreted the Fourteenth Amendment liberty interest in marital privacy in the context of a state-sponsored anticontraception law?

Concurring justices in Griswold sought to place the interest in marital privacy violated by the anticontraception law on other, less "penumbral", constitutional grounds. (381 U.S. 479, 85 S.Ct. 1678; " 'tradition and [collective] conscience of our people' " regarding fundamental rights manifested in Due Process Clause and Ninth Amendment (id., at p. 493, 85 S.Ct. at p. 1686) (conc. opn. of Goldberg, J.); "basic values 'implicit in the concept of ordered liberty' " in Fourteenth [865 P.2d 650] Amendment (id., at p. 500, 85 S.Ct. at p. 1690) (conc. opn. of Harlan, J.); due process denied because no "end" of government could support state law at issue (id., at p. 507, 85 S.Ct. at p. 1694) (conc. opn. of White, J.).) The concurring justices' approach has been preferred to the more amorphous "penumbral" privacy analysis in at least one recent case. (Cruzan v. Missouri (1990) 497 U.S. 261, 279, fn. 7, 110 S.Ct. 2841, 2851, fn. 7, 111 L.Ed.2d 224 [right to refuse medical treatment [7 Cal.4th 29] analyzed as Fourteenth Amendment liberty interest rather than part of right to privacy].)