Book Review: America's Mandated Sterilization—It Seemed Like a Good Idea at the Time

Three Generations, No Imbeciles: Eugenics, the Supreme Court, and

By Paul A. Lombardo

365 pages

If generations of illegitimacy and limited intellect can be used to justify mass sterilization, then count on wiping out most of the southeastern United States, white or black or otherwise. But the consequence would not be merely the intended elimination of welfare-sucking trash—if such an outcome could be predicted. Say goodbye to the works of Tennessee Williams, Faulkner, Capote, and any other writer whose work draws on the freewheeling peccadilloes or horrors, depending on your viewpoint, of the extended Southern family. And say goodbye to anybody like yours truly, whose ancestral history in The Volunteer State contains its share of illiteracy, illegitimacy, and "imbecility" (thank you, US Census Bureau).

But unintended consequences were not considered by proponents of eugenics and sterilization laws in the early 20th century. In their conceit to claim an understanding of inheritance and Darwinian theory, eugenicists believed that the road to public health and lower taxes was paved with the legally mandated sterilization of society's feebleminded and promiscuous citizens—which, in their minds, meant men and women (but mostly women) of the lower classes.

At the center of this sorry time in American history is the legal case of Buck v. Bell, the end-result of Virginia's carefully crafted sterilization law, enacted in 1924. In comprehensive fashion, Georgia lawyer Paul Lombardo lays out this sad case, which was argued before the US Supreme Court, in Three Generations, No Imbeciles, the most detailed account to date of Buck v. Bell and its aftermath.

The Buck in this case was Carrie Buck, a young pregnant woman committed to the Virginia Colony for Epileptics and Feebleminded in 1924 under dubious circumstances. Carrie's mother, Emma, was already a member of the Colony under allegations of mental deficiency and moral turpitude, and Carrie's soon-to-be daughter would be placed in the foster care of the couple who arranged for Carrie's residence at the Colony. Among the 15 of so residents at the state institution selected as candidates by the Colony's Board for sterilization, on the basis of the newly enacted Virginia law, Carrie was chosen as the hapless test case. The argument for Carrie's sterilization would rest on flimsy evidence that 3 generations of the Buck family—including Carrie's infant daughter—constituted inherited imbecility.

Lombardo describes Carrie's legal defense, both at the state and federal levels, as a charade. Buck's anemic appeal before members of the Supreme Court, most of whom sympathized with the eugenics movement, led to a terse ruling in 1927, written by associate justice Oliver Wendell Holmes, Jr, which upheld the Virginia law. In his 3-page opinion, Holmes wrote the famous, cutting phrase, "Three generations of imbeciles are enough," which in fact had no foundation in the Buck family.

On the basis of the Supreme Court decision in Buck v. Bell, many other states (which already had sterilization laws in place) proceeded in relatively unfettered mode to conduct mass sterilization on their less fortunate citizens, and Lombardo writes that the US eugenics movement, bolstered by Buck v. Bell, informed a like-minded program in Socialist Germany, with known consequences.

Remarkably the Supreme Court decision of Buck v. Bell remains intact, although enduring sterilization laws in most states were repealed at the height of the civil-rights movement. (Laws in Washington state and Mississippi remain.) And while the general conceit of today's Americans may be that the constitutionality of legal sterilization won't be tested again before the high court, Lombardo reminds us that the same incentives to improve public health and lower tax burdens exist today and are manifest in selective reproduction methods and judge-mandated orders to not procreate.