The Real Tragedy of Eugenics and a Primer on Buck v. Bell

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Many of the victims were, like Carrie [Buck], perfectly normal both mentally and physically–and they desperately wanted to have children.

-Adam Cohen, Imbeciles: The Supreme Court, American Eugenics, and the Sterilization of Carrie Buck

The tragedy of eugenics is not that it happened to ostensibly non-disabled people. The tragedy of eugenics is that it happened at all. The tragedy of eugenics is that people used the prospect of disability to justify it. The tragedy of eugenics is that anyone, disabled or not, lost their right to choose if they wanted children. They used the prospect of disability to justify sterilizing anyone they saw fit – disabled people, people of color, sex workers, women, low-income people, or a combination of those, for the most part.

Cohen is not alone in asserting Carrie Buck, the subject of the 1927 Supreme Court case Buck v. Bell, was mentally “normal.” Journalist Harry Bruinius discusses it in his book Better for all the World. Paul Lombardo has many words to say about Carrie Buck’s normality as well as that of her daughter Vivian’s in his book Three Generations, No Imbeciles. The Sterilization of Carrie Buck  by J. David Smith and K. Ray Nelson talks about Carrie Buck’s family being actually normal.

Cohen is not alone in therefore implying that there was a correctly targeted group. That Carrie Buck’s sterilization was wrong because she was “normal” and should never have been in the Virginia Colony for Epileptics and the Feebleminded. In one regard, he is correct. Carrie Buck should never have been in that institution. Neither should anyone else have been.

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Carrie Buck was born in Charlottesville, Virginia, in 1906. Eugenics took hold as Carrie grew up. Her father Frank was dead, or had simply left – no one knew. Her mother Emma took to the streets and got put on charity lists to try and take care of her children. Emma may have had substance abuse issues with drugs. Emma sometimes went to having sex with different men to try and make ends meet. She had more children. A family called the Dobbses took Carrie from Emma when Carrie was three or four. Emma Buck eventually was put in the Virginia Colony. When Carrie was seventeen, the Dobbses’ nephew Clarence raped her. A pregnancy resulted. The Dobbses wanted to avoid scandal. They packed her off to the Virginia Colony as “feebleminded” after she gave birth to a girl, Vivian. Facts of the case were not observed. 

The superintendent chose Carrie Buck for a test case of Virginia’s new sterilization law. Carrie went before the board of the institution. They voted to sterilize her. Her appointed guardian filed an orchestrated appeal. It was not really on her behalf. The appeal traveled through all the court systems until it reached the Supreme Court.

Buck v. Bell was a devastating decision by the Supreme Court. The 8-1 decision – the only dissenting member Justice Pierce Butler – said that it was legal to sterilize Carrie Buck, a patient at the Virginia Colony for Epileptics and the Feebleminded. They said it was legal to sterilize people, mostly those in institutions, without their consent. It upheld the Virginia law that had passed three years earlier. Justice Oliver Wendell Holmes, Jr., wrote this infamous statement in the opinion: 

It 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. The principle that sustains compulsory vaccination is broad enough to cover cutting the Fallopian tubes. Three generations of imbeciles are enough.

Buck v. Bell was an injustice done to Carrie Buck. It would have been if it were proven today she actually had an intellectual or developmental disability. It was an injustice to the tens of thousands of people, mostly in institutions, who came after her. It was an injustice to the women in the California prisons who underwent forced sterilization as recently as 2014, and to the women who went before a Tennessee district court prosecutor who forced plea deals involving sterilization. Buck v. Bell has never been overturned in its entirety, permitting legal loopholes. People are still being sterilized today, in the United States and elsewhere.  It is not considered a priority to overturn Buck v. Bell in its entirety. State eugenics laws were not overturned until the 1970s and 80s.

Buck v. Bell reached beyond the borders of the United States. The Nazi Party cited it as justification for some of their war crimes. They drew upon American eugenic ideals. United States officials acted as the primary agents in prosecuting Nazi officials, doctors, and others. Despite its association with Nazism, eugenics is not dead. Nor is its height and prominence a distant memory.

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I encourage you to read the following if you have access to them. Sources to think about, and sometimes critique:

Books that Cost

  • The Nazi Connection by Stefan Kühl
  • Better for All the World: The Secret History of Forced Sterilization and America’s Quest for Racial Purity by Harry Bruinius
  • In the Name of Eugenics by Daniel Kevles
  • The Sterilization of Carrie Buck by J. David Smith and K. Ray Nelson
  • Imbeciles: The Supreme Court, American Eugenics, and the Sterilization of Carrie Buck by Adam Cohen
  • Three Generations, No Imbeciles by Paul Lombardo
  • War against the Weak: Eugenics and America’s Quest to Create a Master Race by Edwin Black
  • A Century of Eugenics in America: From the Indiana Experiment to the Human Genome Era, editor Paul Lombardo
  • Fit to be Tied: Sterilization and Reproductive Rights in America, 1950-1980 by Rebecca Kluchin
  • Inheriting Shame: The Story of Eugenics and Racism in America by Steven Selden

Physical Archives

  • The Carrie Buck archives at the State Library of Virginia (Richmond)

Resources and Articles that are Online/Free