Buck v. Bell

Following is the case brief for Buck v. Bell, 274 U.S. 200 (1927)

Case Summary of Buck v. Bell:

  • A Virginia statute allowed for the forced sterilization of “feeble minded” people to protect the “health of the state.”
  • Carrie Buck, who was mentally disabled, as was her mother and daughter, was ordered to be sterilized pursuant to the statute.
  • Buck challenged the law on constitutional grounds, arguing that it violated due process and equal protection under the Fourteenth Amendment.
  • The lower courts upheld the law and the order for sterilization.
  • The U.S. Supreme Court affirmed the lower courts.  Justice Oliver Wendell Holmes, writing for the majority, stated that the Virginia statute was constitutional, and noted that “three generations of imbeciles are enough.”

Buck v. Bell Case Brief

Statement of the Facts:

The State of Virginia had a statute that authorized the forced sexual sterilization of certain mentally ill people in certain mental institutions.  The purpose of the law was to promote the “health of the patient and the welfare of society.”  The sterilization only took place after a hearing on the propriety of such action.

Carrie Buck was a “feeble minded” woman who was committed to a mental health facility.  Both Buck’s mother and daughter were feeble minded.  It was believed that the mental affliction was hereditary.  Accordingly, the superintendent of the mental health facility recommended sterilization of Buck.

Buck challenged the Virginia statute, arguing that it is a violation of due process and equal protection under the Fourteenth Amendment.

Procedural History:

  • The Circuit Court of Amherst County denied Buck relief.
  • The Supreme Court of Appeal of Virginia also denied Buck relief, upholding the statute.
  • The U.S. Supreme Court granted to hear the case on writ of error.

Issue and Holding:

Did Virginia’s forced sterilization law deny Buck her right to due process and equal protection under the Fourteenth Amendment?  No.

Judgment:

The decision of the Supreme Court of Appeal of Virginia is affirmed.

Rule of Law or Legal Principle Applied:

It is better to impose sterilization on those “manifestly unfit from continuing their kind,” than to wait for such people to commit crimes or “starve for their imbecility.”

Reasoning:

In order for society not to be “swamped with incompetence,” having the sterilization of some mentally incompetent persons is permitted.  Further, the sterilization process cannot occur until after a long hearing process.  Justice Holmes, writing for the majority, noted that “[t]hree generations of imbeciles are enough.”

With regard to equal protection, there is no equal protection problem by the statute focusing only on people in certain mental institutions rather than the public at large.  The “law does all that is needed when it does all that it can,” as it assumes most mentally deficient people are in the relevant institutions.

Significance:

Buck v. Bell is significant because it legitimized eugenic sterilization, and it sparked many states to adopt their own involuntary sterilization statutes.  In fact, Adolf Hitler cited Buck v. Bell as a model for his forced sterilization law to prevent “hereditarily diseased offspring.”  The Nazis even used Buck v. Bell as a defense during the Nuremburg trials following World War II.

Buck v. Bell has not been expressly overturned.  However, Skinner v. Oklahoma, 316 U.S. 535 (1942) made forced sterilization so difficult that it discouraged the practice.  By 1963, sterilization laws were almost entirely out of use.

Student Resources:

Read the Full Court Opinion

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