Supreme Court history eugenics Buck v. Bell forced sterilization Oliver Wendell Holmes Jr.

On May 2, 1927, the United States Supreme Court delivered one of its most contentious rulings in Buck v. Bell, a case that sanctioned the forced sterilization of individuals labeled 'unfit' under state eugenics laws. The decision, written by Justice Oliver Wendell Holmes Jr., has since been widely condemned as a dark chapter in American jurisprudence.

The case centered on Carrie Buck, a young woman who was institutionalized at the Virginia State Colony for Epileptics and Feebleminded. Buck was targeted under Virginia’s 1924 eugenics law, which authorized the sterilization of patients deemed genetically 'unfit' to prevent the transmission of purportedly undesirable traits. Her legal guardian challenged the law, arguing it violated constitutional protections.

In a 8-1 decision, the Supreme Court ruled against Buck, with Holmes famously declaring,

"Three generations of imbeciles are enough."
The Court held that the state’s interest in preventing 'hereditary defects' justified the compulsory sterilization of individuals deemed unfit, setting a precedent for similar laws across the country.

Historians and legal scholars have since criticized the ruling for its reliance on pseudoscientific eugenics theories and its disregard for individual rights. The decision was never explicitly overturned, though later rulings—such as Skinner v. Oklahoma (1942)—narrowed its scope by emphasizing due process protections.

Carrie Buck was sterilized in 1927 and spent the remainder of her life in institutional care. Her case remains a stark reminder of the dangers of state-sanctioned discrimination under the guise of public health.

Source: Reason
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