The Dark Legacy of Forced Sterilization: Carrie Buck's Story

Carrie Buck at the Virginia State Colony for Epileptics and Feebleminded in November 1924, prior to the Buck v Bell Supreme Court case.

Source: Arthur Estabrook/Wikimedia Commons

In an era where reproductive rights are under intense scrutiny, it's worth revisiting a troubling chapter in history: the widespread practice of forced sterilization in the United States.

This controversial practice was institutionalized in the early 20th century and persisted for decades, leaving a dark legacy that still echoes today.

The Era of Eugenics and Forced Sterilization

From 1907 to 1963, over 64,000 individuals, predominantly women, were forcibly sterilized under eugenics laws in the United States.¹

An integral tool of the eugenics movement in the early 20th century United States, the sterilization laws were intended to prevent "inferior unfit specimens" from diluting "the superior American breeding stock," and thus portrayed those deemed unfit or at risk of being deemed unfit as morally depraved and perverse.^{1, 2}

The targeted individuals included disabled persons, immigrants, "fallen women," women of color, and those from lower socioeconomic backgrounds. This deeply invasive practice violated their fundamental rights to bodily integrity, autonomy, and due process.

Carrie Buck's Story

The two main ways in which the compulsory sterilization laws were disrespectful of women's rights were brought to the fore in Buck v. Bell (1927), where the Supreme Court ruled that compulsory sterilization of an "unfit" individual to protect state interests was constitutional.²

In 1924, the board of directors at a mental institution in Virginia issued an order to sterilize the 18-year-old resident Carrie Buck, who they considered to be a genetic threat to society.

Carrie appealed the case, arguing that it violated the Fourteenth Amendment protections of the rights of all adults to be treated equally under the law. The lower courts rejected the appeal, and the case went to the Supreme Court, which ruled 8-1 that Carrie Buck was feeble-minded and promiscuous, and that it, therefore, was in the state's interest to have her sterilized.

Justice Oliver Wendell Holmes, Jr., who wrote the Court's opinion, argued that the public's interest in avoiding "being swamped with incompetence" outweighed a person's interest in bodily integrity.

The Court further stated that:

[i]t is better for all the world if, instead of waiting to execute degenerate offspring for crime or to let them starve for their imbecility, society can prevent those who are manifestly unfit from continuing their kind. [...] Three generations of imbeciles are enough. [emphasis added] (Buck v. Bell, 274 U.S. 200 (1927))

The sole dissenter, Justice Pierce Butler, did not write a dissenting opinion but as a devout Catholic, his vote may have been shaped by his private belief that any form of birth control, including sterilization, interfered with God's will by blocking the male seed.

The Court's disparaging remark that "three generations of imbeciles are enough" referred to Carrie Buck, her late mother, and her young daughter, who were all judged by the Court to be "imbeciles." This case set a legal precedent that validated eugenics-based sterilization.

The Misclassification of "Imbeciles"

Carrie's heartbreaking story is all the more tragic because neither she nor her family met the criteria for being classified as "imbeciles" by the standards of the time.

Edmund Burke Huey's 1912 taxonomy of the "feeble-minded" defined an imbecile as someone with the mental capacity of a seven-year-old child.³

Even if we judge by these horrific outdated standards, Carrie, her mother, and her daughter did not meet the criteria for being "imbecile. Historical documents suggest that all three were of average or above-average intelligence.²

Carrie Buck had received average grades in elementary school, which she attended until her adoptive parents Alice and John Dobb pulled her out of school in 6th grade to have her help with housework.

At the age of 17, Carrie was raped and impregnated by Mrs. Dobb's nephew. To save the family honor, the Dobbs committed Carrie to the mental institution where her late biological mother had been confined for "immorality" after her husband abandoned her.

When Carrie was deemed unfit to raise a child, the Dobbs adopted her daughter Vivian. Vivian made the honor roll at her elementary school, which she attended for two years before she succumbed to measles complications at the age of 8.

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The fact that the Supreme Court upheld the opinion that the coercive sterilization laws were constitutional testifies to how unimaginably disrespectful these laws were of women who had been declared or were at risk of being declared unfit. The disrespect conveyed by the sterilization laws for the unfit painted them as bearers of hereditary vices like moral degeneracy, depravity, or perversity that presented a genetic threat to society.

This bleak picture of the unfit, then, served as justification for upholding the sterilization laws despite their infringement on the targeted individuals' moral rights to bodily autonomy and integrity, not to mention their right to due process of law.

Forced Sterilization Today

Although forced sterilization is now widely condemned as a gross violation of human rights, the Buck v. Bell decision has never been overturned. Virginia did not repeal its sterilization law until 1974, and some states, including Washington, still have such laws on the books.⁴

The legacy of these practices continues to influence discussions about reproductive rights and social justice today, reminding us of the need to safeguard individual autonomy and challenge discriminatory practices.