I found this discussion of unenumerated rights [0] to be helpful in explaining how a right to privacy was derived from the US constitution, and how difficult it is to establish a "test" for unenumerated rights.

[The Griswold case] says the penumbras around the First, Third, Fourth and Fifth Amendment create a right to privacy. So what they're getting at — a penumbra is just a shadow, right? — is that these textual provisions cast these shadows. And those shadows, which all contain this notion of privacy overlap with each other such that they coalesce into a right in its own right, so that the right to privacy under which the right to contraception is protected is derived from the shadows of actual textual provisions.

Very disconcerting that the rights to contraception, same sex marriage, and consensual adult sexual relationships are up for debate because they are not explicitly enumerated in the constitution.

[0] https://www.wbur.org/onpoint/2022/05/31/the-fragility-of-une...