Buck v. Bell
Buck v. Bell is a landmark Supreme Court case from 1927 that upheld a Virginia law permitting the forced sterilization of individuals deemed "feebleminded." The case centered on Carrie Buck, who was classified as feebleminded due to her family's history and was selected as a test case for the eugenics movement, which aimed to improve the population's genetic quality. The Court, in an 8-1 decision led by Justice Oliver Wendell Holmes Jr., asserted that the sterilization law did not violate equal protection rights and emphasized procedural safeguards in the process, including hearings and appeals.
Holmes controversially claimed that society could require sacrifices from those deemed detrimental to its welfare, famously stating, "three generations of imbeciles are enough." This decision spurred many states to adopt similar sterilization laws, leading to the sterilization of over fifty thousand individuals across the United States. While the practice of eugenics and its accompanying laws declined by the 1970s, Buck v. Bell has not been formally overturned and remains a controversial example of how societal values can influence legal standards regarding reproductive rights. The case is often discussed in contemporary debates surrounding reproductive freedom and the ethical implications of eugenics.
Buck v. Bell
Date: May 2, 1927
Citation: 274 U.S. 200
Issue: Compulsory sterilization
Significance: This case upheld the authority of states to require sterilization of any person deemed to be mentally defective.
In 1924 the Virginia legislature passed a statute that required the sexual sterilization of many “feebleminded” persons in state mental institutions. The law provided for procedural rights, including a hearing, appointment of a guardian, approval of an institution’s board, and appeals to the courts. The superintendent of the Virginia State Colony for Epileptics and Feebleminded recommended sterilization for Carrie Buck, who was classified as feebleminded and a “moral delinquent.” Because Buck’s mother and daughter were also alleged to be mentally deficient, she was considered an ideal test case for the law. After state courts decided in favor of the state’s position, the Supreme Court upheld the lower court decisions by an 8-1 vote.
Justice Oliver Wendell Holmes, writing for the opinion for the majority, found that the law did not violate any principles of equal protection and that its procedural guarantees were more than adequate. Accepting the eugenics notions of the day, Holmes argued that if society could call on its “best citizens” to sacrifice their lives in war, it could “call upon those who already sap the strength of the State for these lesser sacrifices.” In this context, he made the notorious statement that “three generations of imbeciles are enough.” Holmes had no way of knowing that Carrie Buck’s child was the result of a rape and that she had actually done acceptable work in school until withdrawn by her guardians to do housework.
Subsequent to Buck v. Bell, many states passed similar sterilization laws, and more than fifty thousand persons were sterilized nationwide. The practice of sterilization, however, was generally discontinued by the 1970’s. Although Buck was never directly overturned, it was based on eugenics theories later considered invalid and appears inconsistent with several of the Court’s decisions upholding reproductive freedom.