U.S. Supreme Court Building
Three Generations No Imbeciles: Eugenics, the Supreme Court and Buck v. Bell
by Paul Lombardo is a thoroughly researched and detailed account of the people, politics and history of the 1927 supreme court case Buck v.Bell, 274 U.S. 200 (1927). In this case, the Court upheld a Virginia statute which, for the “welfare of society”, allowed for the sexual sterilization of persons “afflicted with hereditary forms of insanity…, idiocy, imbecility, feeble-mindedness or epilepsy.” (Virginia Eugenical Sterilization Act, 1924).
At the center of the Buck v. Bell case is Carrie Buck, a teen-age foster child from Charlottesville, Virginia who gave birth to a baby girl in the Spring of 1924. Two months later, at the age of seventeen, Carrie was determined to be feeble-minded, and sent to live at the Virginia Colony for Epileptics and Feeble-minded. This “colony” was essentially an institution used to segregate those thought to be problem citizens from the rest of society. Carrie’s mother, Emma, was also living at the colony, having been committed several years earlier when questions arouse about her morality. Little did Carrie know when she arrived at the colony that she was about to serve as poster child for sterilization.
The lawsuit involving Carrie originated on the heels of growing US interest in the concept of eugenics. Most commonly associated with Hitler’s regime during WWII, eugenics is essentially the idea that the human population can be improved by limiting reproduction of those with what are considered less desirable traits or encouraging reproduction of those with desirable characteristics. By the early 1920s, several states had passed eugenics laws allowing for the sterilization of individuals deemed to have defective genetic traits.
It was unclear whether these laws would survive a constitutional challenge in the courts, however. In fact, the Virginia colony where Carrie was sent had stopped the practice of sterilization several years prior after an embarrassing lawsuit by the family of a woman who had been sterilized there. When Virginia’s new sterilization law was passed in 1924, administrators at the colony wanted to run a “test case” through the courts to be certain they would be protected should any patient or family member decide to sue in the future. They decided that Carrie would be the perfect candidate for their test case. The fact that her mother was also at the colony could be used to demonstrate that mental defects ran in families and also to underscore the importance of using sterilization as a tool to prevent the proliferation of genetic imperfections. And thus began Buck v. Bell, one of the most infamous cases in Supreme Court history.
As stated above, Three Generations is a very detailed account of the Buck v. Bell case and the people and politics surrounding it. In the introduction, Lombardo tells the story of how he became interested in the topic of forced sterilization after reading an article in the newspaper one morning in 1980. As he said, he “couldn’t let go of the story” and spent the next almost thirty years researching and writing about it. Even without knowing this, it is clear that Three Generations is a labor of love. And one that those interested in disability law or history – or even just general United States history – will be glad he undertook. He sheds light on a very shameful part of our history in a readable and entertaining way. Several times while reading this book, I was compelled to put it down and exclaim to the person next to me: “Wow, you are not going to believe this!” before launching into a description of one of the many interesting and, indeed, shocking details of the case Lombardo had revealed. While this is clearly an important book, the fact that I wanted to tell others all about it is, to me, a sign that it is also a very enjoyable and readable book. I would highly recommend this book.