@valleyforge in a weird twist of circumstances, the amendment added to address that criticism (9th: "The enumeration in the Constitution, of certain rights, shall not be construed to deny or disparage others retained by the people.") is the basis for the recognition of the right to privacy* on which Roe was initially decided. The recent Dobbs decision is from a certain perspective what the anti-BoR faction feared - the unenumerated right can be interpreted to exist or not according to the whims of those in power. From another perspective, of course, it's exactly what modern small-government advocates want today.
*not the same thing as today's right to privacy in the context of surveillance. In the Roe context, the phrase was used in the sense of having the authority to make decisions on one's own behalf, much as the sole proprietor makes decisions on behalf of a private enterprise.