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How might the 9th amendment be limited?

User Karissa
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In case you don't know, the 9th amendment is:

"The enumeration in the Constitution, of certain rights, shall not be construed to deny or disparage others retained by the people."

The words are often misunderstood as it is quite a confusing line. It is limited as it doesn't clearly state the meaning and rather leaves people to assume what it means.
User Piris
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