Forty Years

OK, so I'm reading about the "Lochner" period, from Allgeyer v. Louisiana in 1897 up to the constitutional revolution of 1937, in which conservative courts struck down various state regulations under the theory of substantive due process. And I was thinking--1897 to 1937 is forty years. Contemporary substantive due process debates center around the idea of a right to privacy, which was first enunciated in Griswold v. Connecticut in 1965 . . . forty years ago.

Just something I noticed.