May 2, 1927 Buck v. Bell, 274 U.S. 200 is the United States Supreme Court ruling which upheld a Virginia law for sterilizing persons assessed as “socially inadequate” (Lombardo, 2008, p. 5). The case revolved around Carrie Buck, 18 at the time of the trial, who had been ordered sterilized after becoming pregnant illegitimately and institutionalized.

The court based its decision on expert testimony from Arthur Estabrook, a physician with experience at the eugenics records office in Cold Harbor Spring, New York. Estabrook did not re-apply the IQ test that Carrie had been given in the state home, stating instead that he had “talked to Carrie sufficiently” to arrive at his decision that she was feebleminded. (Lombardo, 2008, p. 5) The Court also heard that Carrie’s mother, who had been under government care for some time was also feebleminded and that Carrie’s child Vivian who was then six months old was likely feebleminded as well. Vivian's school reports would later prove this assessment wrong. Not mentioned during the trial was the fact that Carrie’s pregnancy was the result of rape. Instead the court heard from her former teacher how Carrie would send notes to boys, implying her promiscuity (and that she was therefore responsible for her own pregnancy).

This case smoothed the way for many coerced sexual sterilizations across North America and the spreading legislation regarding the sterilization of the “feebleminded.” Carrie’s case also demonstrates the socio-economic and educational factors which influenced the understanding of who was “feebleminded.”

You can view the original court papers here.

-Leslie Baker

• Lombardo, P. (2008) Three Generations No Imbeciles: Eugenics, the Supreme Court and Buck v. Bell, Baltimore: Johns Hopkins University Press.