in Gitlow v New York. The most recent amendment completely incorporated as fundamental was the Second Amendment right to keep and bear arms for personal self-defense, in McDonald v Chicago, handed down in 2010 and the Eighth Amendment's restrictions on excessive fines in Timbs v. Indiana in 2019. Not all clauses of all amendments have been incorporated. For example, states are not required to obey the Fifth Amendment's requirement of indictment by grand jury. Many states choose to use preliminary hearings instead of grand juries. It is possible that future cases may incorporate additional clauses of the Bill of Rights against the states. The Bill of Rights lists specifically enumerated rights. The Supreme Court has extended fundamental rights by recognizing several fundamental rights not specifically enumerated in the Constitution, including but not limited to: The right to interstate travel The right to parent one's children The right to privacy The right to marriage The right of self-defense Any restrictions a government statute or policy places on these rights are evaluated with strict scrutiny. If a right is denied to everyone, it is an issue of substantive due process. If a right is denied to some individuals but not others, it is also an issue of equal protection. However, any action that abridges a right deemed fundamental, when also violating equal protection, is still held to the more exacting standard of strict scrutiny, instead of the less demanding rational basis test. During the Lochner era, the right to freedom of contract was considered fundamental, and thus restrictions on that right were subject to strict scrutiny. Following the 1937 Supreme Court decision in West Coast Hotel Co. v. Parrish, though, the right to contract became considerably less important in the context of substantive due process and restrictions on it were evaluated under the rational basis standard. See also Fundamental Rights Agency of the European Union Inalienable rights Universal human rights References Constitutional law Rights Civil rights and liberties