Three Generations, No Imbeciles: Eugenics, the Supreme Court, and Buck v. Bell
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"Three generations of imbeciles are enough." Few lines from Supreme Court opinions are as memorable as this declaration by Justice Oliver Wendell Holmes Jr. in the landmark 1927 case Buck v. Bell. The ruling allowed states to forcibly sterilize residents in order to prevent "feebleminded and socially inadequate" people from having children. It is the only time the Supreme Court endorsed surgery as a tool of government policy. Paul Lombardo's startling narrative exposes the Buck case's fraudulent roots.In 1924 Carrie Buck-involuntarily institutionalized by the State of Virginia after she was raped and impregnated-challenged the state's plan to sterilize her. Having already judged her mother and daughter mentally deficient, Virginia wanted to make Buck the first person sterilized under a new law designed to prevent hereditarily "defective" people from reproducing. Lombardo's more than twenty-five years of research and his own interview with Buck before she died demonstrate conclusively that she was destined to lose the case before it had even begun. Neither Carrie Buck nor her mother and daughter were the "imbeciles" condemned in the Holmes opinion. Her lawyer-a founder of the institution where she was held-never challenged Virginia's arguments and called no witnesses on Buck's behalf. And judges who heard her case, from state courts up to the U.S. Supreme Court, sympathized with the eugenics movement. Virginia had Carrie Buck sterilized shortly after the 1927 decision.Though Buck set the stage for more than sixty thousand involuntary sterilizations in the United States and was cited at the Nuremberg trials in defense of Nazi sterilization experiments, it has never been overturned. Three Generations, No Imbeciles tracks the notorious case through its history, revealing that it remains a potent symbol of government control of reproduction and a troubling precedent for the human genome era. Publishers Weekly Law professor and historian Lombardo does a superb job of revealing, for the first time, all the facts in the infamous Buck v. Bell case of the 1920s, the Supreme Court decision ratifying Virginia's compulsory sterilization of "feebleminded" people. In the majority decision, Chief Justice Oliver Wendell Holmes Jr. called the plaintiffs "manifestly unfit" both mentally and morally, and insisted that "three generations of imbeciles are enough." This decision-which has never been overturned-led to tens of thousands of involuntary sterilizations. Lombardo interviewed the last survivor of the three Buck women who were plaintiffs; turned up indisputable evidence that there was no feeblemindedness in that family; unearthed previously unknown correspondence of Carrie Buck's attorney, who, believing the law to be necessary, mounted a deliberately insufficient defense; and documented the private family tragedy (an incestuous rape and resulting pregnancy) that lay behind the Bucks' encounter with doctors bent on exploring eugenics. His book is a testament to injustice and to ignorance-not that of the Buck women, but rather of powerful doctors, attorneys and Supreme Court justices. 17 b&w photos. (Oct.)Copyright © Reed Business Information, a division of Reed Elsevier Inc. All rights reserved.
Prologue: The Expert Witness 11 Problem Families 72 Sex and Surgery 203 The Pedigree Factory 304 Studying Sterilization 425 The Mallory Case 586 Laughlin's Book 787 A Virginia Sterilization Law 918 Choosing Carrie Buck 1039 Carrie Buck versus Dr. Priddy 11210 Defenseless 13611 On Appeal: Buck v. Bell 14912 In the Supreme Court 15713 Reactions and Repercussions 17414 After the Supreme Court 18515 Sterilizing Germans 19916 Skinner v. Oklahoma 21917 Buck, at Nuremberg and After 23618 Rediscovering Buck 250Epilogue: Reconsidering Buck 267Acknowledgments 281App. A The Supreme Court Opinion in Buck v. Bell, by Justice Oliver Wendell Holmes Jr. 285App. B Virginia Eugenical Sterilization Act, 1924 288App. C Laws and Sterilizations by State 293Notes 295A Note on Sources 355Index 357
