Supreme Court Endorses Forced Sterilization in Buck v. Bell Eugenics Decision

The Supreme Court rules 8-1 in Buck v. Bell to uphold Virginia’s compulsory sterilization law, providing constitutional blessing for the eugenics movement’s campaign to sterilize those deemed “unfit.” Justice Oliver Wendell Holmes writes for the majority that the state may sterilize individuals judged “feebleminded” to prevent transmission of hereditary defects, declaring: “Three generations of imbeciles are enough.” The decision validates forced sterilization as a legitimate exercise of state police power and accelerates eugenics programs nationwide.

Carrie Buck, the plaintiff, was an 18-year-old committed to the Virginia Colony for Epileptics and Feeble-Minded after becoming pregnant from rape by her foster family’s nephew. Authorities labeled her “feebleminded” based on her poverty and illegitimate pregnancy, not any actual cognitive testing. Her mother Emma was institutionalized on similar grounds. Carrie’s daughter Vivian, whom authorities also deemed defective as an infant, would later prove to be of normal intelligence before dying in childhood. The “three generations” Holmes cited were a rape victim, her impoverished mother, and an infant - not products of hereditary defect but of poverty, sexual violence, and institutional bias against poor women.

Harry Laughlin of the Eugenics Record Office, who had provided expert testimony characterizing Carrie as genetically defective without ever examining her, would later receive an honorary degree from the University of Heidelberg for his contributions to “racial hygiene” - the Nazi eugenics program that cited Buck v. Bell as precedent. Following the decision, more than 60,000 Americans were forcibly sterilized under state eugenics laws, disproportionately targeting poor women, immigrants, people of color, and those with disabilities. Buck v. Bell has never been explicitly overruled and remained cited as precedent into the 21st century. The case demonstrates how scientific racism captured elite institutions, with the nation’s highest court endorsing pseudoscience to justify state violence against the most vulnerable.