Eugenics & The Story of Carrie Buck Analysis

Carrie Buck was a pregnant, 18-year-old girl when she was institutionalized at the Virginia State Colony for Epileptics and Feebleminded in 1924. She was sent to the institution after a petition was passed by her foster parents after Carrie claimed she was raped and impregnated by her foster parents’ nephew.  A Virginia Act, The Eugenical sterilization Act, was passed in 1924, reciting that the sterilization of people with mental deficiencies would improve society, and promote general welfare, Carrie Buck being one of these people.  Carrie’s case was argued April 22, 1927, and decided May 2, 1927.  Buck v. Bell was a revolutionary beginning to the normalization of involuntary sterilization of those deemed defective. 

Under the belief that an involuntary sterilization was against her rights, Carrie Buck took Dr. John H. Bell of the Virginia State Colony for Epileptics and Feebleminded to court.  In the making of the case, it was found that both Carrie and her mother, Emma, and her six-month year-old daughter, Vivian, all lacked mental skills. The doctors at the institution believed that this mental inadequateness was hereditary, and Carrie was to be sterilized to improve her health, and the health of society, in hopes her sterilization would cut off her inadequate bloodline. Buck believed making her sterile forcefully was against her rights as a person with disabilities, but no criminal record.  The judgement said that Carrie was the offspring of inadequate parents, and her sexual sterilization would not harm her health, and her welfare and welfare of society would be promoted by her sterilization. As no harm was to come to Carrie, her sterilization seemed unarguable.  Chief Justice, Oliver Wendell Holmes Jr., stated “Three generations of imbeciles are enough.” The Supreme Court ruled it was not in violation of constitutional rights to forcefully sterilize those with disabilities. Carrie Buck was sterilized on October 19th, 1927, about 5 months after the trial’s verdict. She was the first of many to be sterilized after the 1924 Eugenical Sterilization Act passed.  Carrie Buck’s efforts for her rights were vigorous, but she was unable to persuade the court in her favor.

After the Buck v. Bell case decided the Eugenical sterilization Act of 1924 was constitutional, the use of involuntary sterilization became increasingly normalized. In 1927, the Supreme Court found the Eugenical Sterilization Act was not only constitutional, but beneficial. A similar case took place a decade before Buck v. Bell called the California “Asexualization Acts''. This led to the sterilization of 20,000 Mexican and Black people who were believed to be mentally ill. The laws of California reportedly inspired Hitler and his Nazi party in the 1930’s while the formulization of their own eugenic policies was underway. Hitler wrote, “There is today one state in which at least weak beginnings towards a better conception [of citizenship] are noticeable. Of course, it is not our model German Republic, but the United States'' while discussing the Asexualization Acts of California. As the epidemic of sterilization grew rapidly throughout the globe, it also spread wider throughout the nation. Nearly 70,000 people were sterilized in the 20th century, predominantly women of color in the working class. Nearly one-third of Puerto Rican women were persuaded to be sterilized from the 1930’s to the 1970’s after government officials claimed the economy of Puerto Rico would improve due to reduced population. The movement of American Eugenics began in the late 1800’s, and from the beginning were based on racism and targeted young women deemed inadequate. The goal of American Eugenics was to create an elite breed of humans by “breeding out” traits and people that were unappealing, such as the mentally ill, or those who were not white. Up until the 20th century, the eugenics movement was accepted, and many states had federally funded Eugenics boards. The sterilization of the deficient population was one of the most effective ways to stop the reproduction of inadequate humans and create a superior population. The Court is still yet to explicitly overturn Buck v. Bell.  The impact of Buck v. Bell along with similar cases began the nationwide normalization and acceptance of the Eugenics movement.

In Present times, Eugenics are still happening, and Carrie Buck’s importance in history has not been forgotten. In 2001, citing Oliver Wendell Holmes’s decision, the Eight Circuit Court of Appeals ruled “involuntary sterilization is not always unconstitutional”, stating that in some cases, the use of eugenics is acceptable and constitutional. Although the use of involuntary sterilization has reduced rapidly, the idea of eugenics will not simply vanish. Between 2006 and 2010, 150 inmates in California prisons were sterilized without consent. In the summer of 2016, reduced jail time was offered by a Tennessee judge, if the inmates would undergo vasectomies or receive contraceptive implants. The use of Eugenics in the United States became intolerable, yet it has not disappeared. IN the recent cases involving involuntary sterilization, it has been able to fly under the radar by changing the way in which they are performed.  Involuntary sterilizations are still legal, and performed. If the legal guardian believes their disabled child will be better off sterilized, even if they do not make that decision themselves, they can be legally sterilized. Although the Supreme Court never overturned Buck v. Bell, state statutes allowing for eugenic sterilization have been repealed. 

Although Buck v. Bell was not the first case involving sterilization and eugenics, it was one of the most defining of the topic. As involuntary sterilization was used more and more as a weapon against the “defective”, the more it was viewed as an efficient way to create a breed of superior humans. At the time, those of Hispanic descent, Black people, the Feebleminded, and other such inferior groups were undesirable, and therefore were to be bred out through Eugenics. The Eugenic movement was adopted into many situations, such as Hitler’s mass genocide. To this day, un-consensual sterilization and the idea of Eugenics have not disappeared, and likely never will. The importance and significance of Buck v. Buck and other similar cases are still discussed to this day. 

Works Cited

"Buck v. Bell (1927)." In American Government, ABC-CLIO, 2020. Accessed December 14,       2020.

Richard, Penny L. “Carrie Buck”. Britannica School. Accessed February 1, 2021.

“Buck v. Bell: The Test Case for Virginia’s Eugenical Sterilization.