Buck v Bell: The Supreme Court Case That Fueled the Eugenics Movement

Overlooked History is a Teen Vogue series about the undersung figures and events that shaped the world.
Carrie Buck  with her birth mother Emma Buck at the Virginia State Colony for Epileptics and Feebleminded
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There was nothing wrong with Carrie Buck. Nonetheless, several well-respected men had a tremendous interest in proving that there was. Harry Laughlin, director of the Eugenics Record Office, who had never met Carrie, swore that she was an immoral, lying prostitute. Aubrey Strode, a former Virginia legislator, who authored the Virginia Sterilization Act of 1924, argued in front of the Supreme Court that Carrie's reproductive capabilities needed to be taken away. Although it was of very little interest to anyone at the time, Carrie’s harrowing experience in the spotlight stemmed primarily from circumstances out of her control.

Carrie Buck, born in 1906, grew up as the daughter of a desperately impoverished single mother before becoming the foster child of a well-off couple. She was taken out of school after the sixth grade to work full time cleaning the houses of well-to-do families. Carrie was raped at the age of 16 by her foster mother’s nephew, becoming pregnant as a result. Her foster parents reacted viciously and had Carrie declared mentally incompetent and sent to the Virginia State Colony for Epileptics and Feeble-minded. The colony was created as a result of the burgeoning eugenics movement and sought to segregate those who were seen as genetically inferior so that their “defects” might be kept from spreading through reproduction.

The American eugenics movement exploded onto the political scene in the early 20th century, promising, in the words of breakfast cereal magnate and ardent eugenicist John Harvey Kellogg, “a new and glorified human race which sometime, far down in the future, will have so mastered the forces of nature that disease and degeneracy will have been eliminated.” If the genetically inferior could be taken out of the equation, the belief went, this utopian future could be achieved. The evidentiary foundations of the eugenics movement were rather ludicrous and pseudo-scientific, but nonetheless, counted Americans such as Theodore Roosevelt and Woodrow Wilson among its supporters.

As Andrea DenHoed explained in The New Yorker, the colony in which Carrie found herself was not unique; many such institutions existed to segregate the genetically undesirable. What separated Carrie from a host of women in similar situations was that the place she wound up in was run by a particularly ambitious man. Dr. Albert Priddy, the superintendent at the Virginia colony, had already succeeded in isolating perceived undesirables from the broader population. But he didn’t stop there. Rather than segregating those deemed feeble-minded, his institution and others like it could simply sterilize them all. With the ability to reproduce taken away, the residents could be let back into the general population without any risk of furthering the bloodlines that threatened a superior, Aryan fantasy race.

Although the Virginia Sterilization Act of 1924 granted legal protections to those who performed the procedure, similar state laws had been struck down by the courts. With this in mind, Priddy opted to bring a test case to see if it could pass legal muster before any sterilizations were actually carried out. Carrie was chosen for this rather sinister undertaking because she seemed to present the strongest case about the dangers of an unregulated gene pool, according to DenHoed. She was labeled a “middle-grade moron,” meaning that she had a slightly below average IQ but could theoretically pass as ordinary and breed with her genetic betters. She’d already given birth to a child who was similarly stigmatized without any evidence, thus giving the false impression that Carrie was indeed genetically inferior and capable of passing on those genes.

That is how Carrie Buck found her case in front of the Supreme Court, where men argued whether or not they would allow her to have more children. Irving Whitehead, who served as Carrie’s defense attorney, had been childhood friends with Aubrey Strode (who was arguing in favor of having Carrie sterilized) and formerly served on the board of the Virginia colony. Carrie, clearly without adequate legal representation, found herself on the losing side of an 8-1 vote of the highest court, in a case designated Buck v. Bell. (Priddy died during the court battle and the case took the name of his successor.) Writing for the majority, Associate Justice Oliver Wendell Holmes, Jr. offered a bone-chilling justification: “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.” In a reference to Carrie’s mother and daughter, Holmes opined, “Three generations of imbeciles are enough.”

Buck v. Bell, which remains legal precedent, despite being partially repudiated in the 1942 case Skinner v. Oklahoma, gave the American eugenics movement the legal backing it needed to achieve its wildest dreams. The exact number of forced sterilizations that were performed as a result of the movement’s success is unknown but estimated to be north of 60,000. During the Nuremberg trials, a lawyer for Nazi defendants cited the case to help justify their own crimes against humanity.

Justice Holmes, who was 86 at the time of his ruling, became the oldest sitting justice in the history of the Supreme Court, retiring in 1932 at the age of 90. He died with his reputation intact, two days shy of turning 94. His house became a national landmark in 1972 and his name adorns a middle school in Los Angeles.

Carrie’s family was not as lucky. As The New York Times noted in a 1980 article, Carrie’s sister Doris was sterilized without her consent during an operation that she believed was for appendicitis. Only as a 67-year-old woman did Doris learn why she had never been able to realize her dream of having children. Carrie’s daughter, Vivian, was taken from her and raised by the same foster parents who had committed Carrie after she had been raped. Vivian was declared mentally deficient by a social worker who examined her when she was just six months old. Explaining her diagnosis, the social worker testified, “There is a look about it that is not quite normal, but just what it is, I can’t tell.” Despite difficulties with math classes, Vivian did quite well in school, even earning a spot one term on the honor roll. She died from an unknown illness when she was just eight years old.

Little record exists of Carrie’s life after the Supreme Court case. She was sterilized soon after and eventually released from the Virginia colony. She spent her final years hungry and freezing in a small shack before she entered a nursing home in the early '80s, according to a paper in The Catholic Lawyer. Those that visited her observed a woman who enjoyed reading the newspaper and doing crossword puzzles with friends. When medical experts examined Carrie toward the end of her life, they found no evidence to suggest she was not of “normal intelligence.”

Among some of her final recorded words, Carrie expressed forgiveness for those who had wronged her. “I tried helping everybody all my life, and I tried to be good to everybody. It just don't do no good to hold grudges.” She died in 1983 at the age of 76. In a remarkable act of pure coincidence, Carrie was laid to rest mere feet away from her daughter, Vivian, at last reuniting a tortured mother with her long-lost child.

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