Buck V Bell Case

In 1927, there was an infamous Supreme Court case in Virginia that would be controversial and affect the lives of the mentally ill for many years. This was known as the case, Buck v Bell, which ruled in the favor of the sterilization of Carrie Buck, who was deemed “mentally unfit” to reproduce (Caldwell 1). Justice Oliver Wendell Holmes Jr. ruled that it did not violate the Fourteenth Amendment and quotes that “three generations of imbeciles are enough” (Wright 1). This court case led to an improper decision for Carrie Buck due to a law that negatively impacted the entire United States because it limited the rights of mentally challenged citizens in history for a large part of the remainder of the twentieth century.
In 1924, the Eugenical

Sterilization Act was passed and Virginia Colony officials wanted to test the new laws legality on Carrie Buck, a young “feebleminded” woman who gave birth to an illegitimate child (Caldwell 1).

A fact that was never brought up during the court cases was that Buck’s pregnancy was because she was raped by a nephew of the foster parents. Buck’s mother, Emma Buck, was also accused of having hereditary traits of illegitimacy. The right to enforce sterilization was first challenged in the Circuit Court of Amherst County (Caldwell 3). In court, Buck was in trail against Albert Priddy, the Virginia Colony’s superintendent, and Aubrey E. Strode, the man who established the Sterilization Act. Irving P. Whitehead was Buck’s unjust attorney, who provided a weak defense for Buck, because Whitehead knew Priddy and Strode personally, professionally, and politically for many years. Whitehead did not call any witnesses during the trial while Strode called four “expert” witnesses to prove that Buck was feebleminded (Caldwell 3). The Amherst County Circuit Court declared the lawfulness of the Sterilization Act and the case then went to the Virginia Supreme Court of Appeals. Priddy died in January 13, 1925 before appeals have decided to hear the case and Dr. John H. Bell took his place as superintendent. Later that year, the Virginia Supreme Court of Appeals agreed with the

ruling of the Amherst County Circuit Court. Thus, a petition of judicial writ was filled and submitted to the U.S. Supreme Court. The Supreme Court heard the oral arguments on April 22, and on May 2, 1927, they made the decision to sterilize Carrie Buck 8 to 1 and upheld the law that permitted it. Chief Justice Oliver Wendell Holmes Jr. reckoned on the previous Jacobson v. Massachusetts (1904) case and the experts of Buck’s first trial led the Chief Justice to announce that “Three generations of imbeciles are enough” (Caldwell 4). Carrie Buck was later sterilized on October 19 that same year, but Buck was unaware until 1980. Moreover, she was not taken back by her foster family where her child, Vivian, was being raised.
Throughout history of American law, there was no other case like Buck v.

Bell. It was the first time the Supreme Court order someone to be operated, who did not want to be operated. This case was based of false facts, false theories, and false science. Eugenics was first started in England by a man named Francis Galton, a half-cousin of Charles Darwin, developed the concept of eugenics that could improve the gene pool from future generations of physically or mentally disabled (Wright 2). Eugenicists believed that if two people of healthy genes reproduced, and the ones with improper genes did not, then it would improve humanity from disability. Eugenics was greatly adopted by the leaders in America including Theodore Roosevelt and Alexander Graham Bell. Theodore Roosevelt after leaving the White House states, “I wish very much that the wrong people could be prevented entirely from breeding… Feeble-minded persons [should be] forbidden to leave offspring behind them” (Roy 1). Many universities, including Harvard, began offering classes in eugenics as it began to have been a form of incompetence prevention. The case was used as a model to look back to for not only the United states, but all over the world. For example, Adolf Hitler studied eugenics and even published a book known as “Mein Kamph” which proved his deep understanding of American eugenics. Thus, led to the rise of the Nazi Regime sponsoring research and passing laws that eliminated genetic problems such as birth

defects. The Nazis followed America in eugenic sterilization. There was cooperation between the American eugenicist and scientists with the Nazis which led them to sterilize as much as 370,000 people (Lombardo 1). When the Nazis leaders are trialed at Nuremberg, they Nazis cite back to what America’s Supreme Court stated that sterilization was constitutional from the words of Chief Justice Oliver Wendell Holmes Jr.
Carrie Buck was wrongfully accused of being feebleminded. One of the ways she was tested was through poor IQ testing that did not test intelligence properly. One of the questions she was asked was, “What do you do when a playmate hits you?”, which is not a proper or relevant to the ideal IQ test question (Cohen 1). The Virginia Colony appointed Irving P. Whitehead as Buck’s lawyer, who clearly nor on her side, because he had good relationships with Albert Priddy and Aubrey E. Strode and wanted to see Buck sterilized. During the 1920s, The American Civil Liberties Union was mostly pro-eugenics and there were no advocacy groups to defend people like Buck (Cohen 3). The only Supreme Court Justice who sided with Buck was Catholic. The Catholic people were the ones who oppose the eugenics law. They do not want people to be judged by their physical characteristics and incapabilities, but rather who they are on the inside. During Carrie Buck’s old age, many people who knew her stated that she was not feebleminded because she would do activities such as working on puzzles and reading the newspaper. It was not until 1974 that Virginia had repealed the sterilization law of 1924. Recently, the state of Virginia decided to compensate those who were wrongfully sterilized with $25,000 but many have already died before they could receive it.
Buck v. Bell was a case that was dealt with improper evidence, framed defense, and false theories which caused one of the worst decisions in U.S history. This court case led to an improper decision for Carrie Buck due to a law that negatively impacted the entire United States because it limited the rights of mentally challenged citizens in history for a large part of the remainder of the twentieth century. It showed how powerful our government leader’s beliefs can have on a minority group of individuals, and how something that is popular with many individuals, is not always moral.