In 1927 the Supreme Court ofthe United States reviewed and upheld as constitutional a Virginia state law allowing for the compulsory sterilization of feebleminded and defective persons. Carrie Buck, a Virginia teenager, was declared feebleminded, despite the fact that she was a good student and intellectually at par with her classmates; she also was to be sterilized under the Virginia law. Virginia’s law and the Supreme Court decisions to uphold it were influenced by the eugenics movement, which promoted social controls to improve hereditary qualities and to regulate genetic deficiencies in human beings.
Carrie Buck’s mother, Emma, a widow who lived at the margins of society in Charlottesville, Virginia, was deemed feebleminded due to her “shiftless and immoral” lifestyle and placed in the Colony for Epileptics and Feebleminded for life. Unable to care for Carrie after the death of her husband, Emma gave her into the care of the Dobbs family. Carrie became their house servant. Although she was doing well in school, the Dobbses withdrew her, so she could do more service for the family and also be lent to other families for chores. In 1923 Carrie became pregnant. Despite Carrie’s claim that she had been raped by a family nephew, Mr. Dobbs, afraid of the shame Carrie’s situation would bring to his family, filed commitment papers and claimed that Carrie was feebleminded. Because of her pregnancy and her mother’s feebleminded status, Carrie became a prime target for sterilization by the Virginia Commission on Feeblemindedness.
After giving birth to her child, Vivian, Carrie was quickly condemned to the Colony for Epileptics and Feebleminded. There she was to be sterilized to promote the welfare of society. To build a case that Carrie’s genetic stock was defective, her seven-month-old daughter was examined and deemed “not quite normal.” Harry Laughlin of the Eugenics Record Office and Carnegie Institution, without ever meeting or examining Carrie, gave a deposition declaring Carrie Buck a mental defective and socially unfit. Although the evidence against her was weak, the U. S. Supreme Court upheld the institutionalization and sterilization of Carrie Buck.
The Court’s decision was written by Oliver Wendell Holmes, a Progressive justice and a supporter of eugenics. Holmes argued that the feebleminded sapped the strength of the state and that compulsory sterilization would prevent society from being “swamped with incompetence.” Furthermore, he argued that “Three generations of imbeciles are enough.” Justice Pierce Butler, a conservative on the Supreme Court, was the only dissenter. The Supreme Court’s affirmation of the Virginia sterilization law in Buck v. Bell allowed for the passing of similar laws in 30 states. Some 50,000 people were sterilized without their consent as a result of those laws. Buck v. Bell became a legal model for the Nazis during the Holocaust when 350,000 people were sterilized. Buck v. Bell was never directly overturned. In Skinner v. the State of Oklahoma (1942), the Supreme Court found that the state could not sentence criminals to compulsory sterilization, because the categories by which sterilization was imposed were “invidious discrimination” that undermined equal protection under the law. Eugenic sterilization declined in the aftermath of World War II.
See also MEDiciNE; social work.
Further reading: Edwin Black, War against the Weak: Eugenics and America's Campaign to Create a Master Race (New York: Thunder’s Mouth Press, 2003); David Smith and K. Ray Nelson, The Sterilization of Carrie Buck (New Jersey: New Horizons Press, 1989).
—Jeffrey Powell
World History
