Skinner v. Oklahoma
Skinner v. Oklahoma is a landmark Supreme Court case from 1942 that addressed issues of compulsory sterilization and reproductive rights. The case emerged in the context of Oklahoma's law, which allowed the sterilization of individuals classified as "habitual criminals" following multiple convictions for certain crimes, while excluding white-collar offenses. The law was influenced by eugenics, a movement that sought to control reproduction based on the belief that criminality and mental defects could be inherited. The case involved Jack Skinner, who was ordered to undergo a vasectomy after multiple convictions.
The Supreme Court unanimously ruled that the Oklahoma law was unconstitutional, citing violations of the equal protection clause of the Fourteenth Amendment. Justice William O. Douglas, writing for the majority, articulated that the state failed to provide evidence justifying the law's discriminatory application. He emphasized that the right to procreate is a fundamental civil liberty. This ruling not only repudiated the eugenic principles underpinning the law but also laid the groundwork for future discussions on privacy rights in reproductive matters. Skinner v. Oklahoma remains a significant case in the realms of civil rights and reproductive justice, reflecting the complexities of legal and ethical considerations surrounding personal autonomy.
Skinner v. Oklahoma
Date: June 1, 1942
Citation: 316 U.S. 535
Issue: Compulsory sterilization
Significance: The Supreme Court ruled that states could not require sterilization because of criminality or moral turpitude.
Oklahoma, as well as other states in 1942, authorized sterilization of “habitual criminals” after multiple convictions for enumerated crimes of “moral turpitude.” The Oklahoma law did not apply to those persons guilty of embezzlement and other white-collar crimes. The justification for the law, inspired by the eugenics movement, was the theory that some traits of criminality and mental defect were biologically inherited. Skinner, who had been convicted once for stealing chickens and twice for armed robbery, was ordered to submit to a vasectomy.
By a 9-0 vote, the Supreme Court ruled that the law was unconstitutional, but two justices disagreed with the majority’s constitutional reasoning in the decision. Speaking for the majority, Justice William O. Douglas found that the law violated the equal protection clause of the Fourteenth Amendment. The state had presented no evidence that the tendency to engage in larceny was more likely to be inheritable than the tendency to commit embezzlement. Although Douglas did not base the decision on substantive due process, he nevertheless emphasized that the liberty of procreation was “one of the basic civil rights of man.” For this reason, Skinner helped prepare the foundation for a later constitutional right of privacy.