Buck v. Bell

Lochner EraDue Process

The Court upheld forced sterilization of the so-called feebleminded, with Justice Holmes declaring that three generations of imbeciles are enough.

Overview

Virginia sterilized Carrie Buck, a young woman labeled feebleminded, under a eugenics statute. Her lawyer, colluding with the state, offered a weak defense. Justice Holmes, for an 8-1 majority, upheld the law on utilitarian grounds, reasoning that society could prevent being swamped with incompetence, and that sacrifice for the public welfare was justified. Thousands of sterilizations followed nationwide, and the reasoning echoed in later decisions before being repudiated in spirit. Never formally overruled, Buck v. Bell stands as an enduring warning about the abuse of scientific authority by courts and legislatures.

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