Introduction
This analysis entails a critical analysis of a court case, Buck v Bell, which was decided on May 2, 1927. The case began in the Virginia State Court system before proceeding to the U.S. Supreme Court. The main argument of the case concerned Carrie Buck’s proposed sterilization, a judgment that was passed by the State of Virginia’s court system. The ruling allowed the state to sterilize Carrie Buck to prevent her from giving birth to more children so as not to pass on her defective genes associated with mental disability. Nonetheless, she appealed the ruling, but, unfortunately, the U.S Supreme Court upheld the decision in an eight to one vote. In a historic verdict, Justice Oliver W. Holmes hailed that the event was unfortunate and the three generations of imbeciles were enough. In contrast, only Justice Pierce Butler disagreed with the majority’s opinion although he did not explain his decision. Consequently, Carrie Buck was forcibly sterilized setting the stage for similar acts against any American in similar circumstances in the future. On this basis, this study seeks to provide an overview of the court proceedings, information about individuals involved, reactions from supporters and detractors, and the historical context of the case.
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Summary of the Court Case
The Buck v Bell case concerns citizenship rights and equal protection of the laws as enshrined in the Fourteenth Amendments to the U.S. Constitution. In this case, Carrie Buck felt that her right to equal protection had been violated in the sense that the state statute allowed for her forceful sterilization as a basis for the protection and health of the State of Virginia. By March 20, 1924, the State of Virginia had endorsed and adopted a law that legitimized eugenics. As a result, individuals who were considered to be unfit or socially inferior were subjected to compulsory sterilization. These facts provide a basis for evaluating the case as follows.
With compulsory sterilization law in force, Carrie Buck was declared to be socially inadequate having conceived and given birth at a young age. Like other individuals considered being feebleminded and promiscuous, Carrie Buck was committed to the Virginia State Colony for Epileptics and Feebleminded Persons. The medical authorities under the directive of the state sought to sterilize Carrie Buck on the basis that she together with her mother and daughter were of subnormal intelligence. In response, Carrie Buck challenged the directive because the sterilization law furthered no legitimate state interests. Consequently, the law deemed to violate the Due Process Clause of the Fourteenth Amendment.
While Carrie Buck was not directly involved in the case, the lawyers on both sides of the case presented their arguments although they were in constant contact with one another, which is illegal.
Buck v Bell case was sponsored by Albert Priddy and other eugenicists (plaintiff) who hired the lawyers to represent the accused and themselves in the case. The main argument against Carrie Buck was presented in the form of a Stanford Revision of Binet-Simon Test results whereby it was argued that the accused had a record of a life of immorality, prostitution, and untruthfulness. Equally, it was contended that Carrie Buck was not self-sustaining in the sense that she grew up in a foster home. Furthermore, she had an illegitimate child who was said to be ‘not quite normal’ according to Laughlin’s statement. Lastly, citing evidence of the hereditary nature of the defendant, it was decided that Carrie Buck was from a socially inadequate family background having been taken from her mother at the age of four years and given to a foster family. Based on these statements, the judges in the Virginia State Court and Virginia Court of Appeals upheld the decision to sterilize Carrie Buck.
Determined to assert her rights, Carrie Buck appealed the ruling up to the U.S. Supreme Court. In April of 1927, the U.S. Supreme Court judges reviewed the records from the original trial and the appeals court and decided the case in an 8 to 1 vote. Thus, the U.S. Supreme Court held the affirmed the constitutionality of Virginia’s law, which allowed the state to enforce the sterilization. In his submission, Justice Holmes upheld the law citing that it was reasonable for the state to implement the code in the name of public welfare. This assertion implied that as long as the due process was followed in compliance with the statute, the State of Virginia had a right to safeguard the public from the ‘manifestly unfit from continuing their kind.’ Justice Holmes concluded his statement saying ‘three generations of imbeciles are enough.’
For this case, there was no amicus curie except for the sponsors of the case who were primarily the plaintiffs. In my assessment, the U.S. Supreme Court judges did not accord the appellant the chance to defend herself, but instead hurriedly made the ruling based on court transcripts. As stated earlier the case was decided based on an eight to one vote with the dissenting judge failing to highlight his reservations. Hence, in every aspect, Carrie Buck was not granted a fair hearing rendering the judgment unjust in my opinion.
Information about the Individuals Involved
Based on the case file, Buck v Bell was first prosecuted as Buck v Priddy. Initial appearances were made on November 18, 1924, in the Circuit Court for Amherst County. Nonetheless, because Buck’s lawyer, Irving Whitehead, failed to dispute the evidence presented against her clients, the judge upheld the decision to sterilize the accused. Dissatisfied with the outcome, the defendant appealed the decision through her lawyer in the Virginia Court of Appeals, which also ruled against her. Having gone through the Virginia State Court system, the case proceeded to the U.S. Supreme Court as Buck v Bell. The change in name is attributed to the fact that by the time the case was introduced in U.S. Supreme Court in April of 1927, Albert Priddy was dead. Consequently, Dr. John Hendren Bell, the new superintendent of the Lynchburg Colony assumed this responsibility. At the U.S. Supreme Court, the judges reviewed court transcripts and a made a ruling by voting eight to one to uphold the Virginia Court of Appeals decision. Therefore, the Circuit Court for Amherst County, the Virginia Court of Appeals, and U.S. Supreme Court were the courts involved in the case.
The renowned judges involved in the case include Justice Oliver W. Holmes and Justice Pierce Butler. The former affirmed the Virginia Court of Appeals decision and confirmed that the public welfare outweighed the interest of the accused or other individuals in similar circumstances regarding their bodily integrity. On the other hand, Justice Pierce Butler was the only with a contrary opinion although he did present his written submission to justify his dissenting opinion. Primarily, his decision may have been informed by the fact that he was a devout Catholic.
Individual participants include Carrie Buck, her mother, Emma, Harry Laughlin, Irving Whitehead, Alberty Priddy, and Dr. John Hendren Bell. Carrie Buck is the defendant and the main character in this case. To provide context to the situation, Carrie Buck was taken ways for her mother at the age of three and presented to the Dobbs, her adoptive family. In her new found home, Carrie Buck was mistreated and burdened endless chores within her adoptive family and few neighbouring households. At some point, she was raped by one of the Dobbs’s family member and got pregnant (Facing History and Ourselves, 2019). As a result, the Dobbs plotted to rid themselves of her leading to her predicaments in the court systems.
Harry Laughlin played a critical role in the case in the sense that he prepared the evidence presented. As an officer of Eugenics Record Office, it was important for Harry Laughlin to showcase that Buck was likely to pass on the defective genes to her offspring as mentioned by the colony (Facing History and Ourselves, 2019). It is on this basis that the court decided that Buck was a potential parent for a defective offspring.
Albert Priddy and Dr. John Hendren Bell are the plaintiffs in the case. Albert Priddy approved the prosecution of the claim under the newly adopted law that permitted compulsory sterilization of individuals who were thought to be unfit to procreate. As the superintendent of the colony, the case was prosecuted in his name. Albert initiated the case in the sense that he hired a lawyer for Buck in conjunctions with other eugenicists to determine the legality of the decision by the officials of the Lynchburg Colony to sterilize the accused. On behalf of Albert, Aubrey Strode, his lawyer, in partnership with the Lynchburg Colony provided evidence in the court of law to justify the sterilization of Carrie Buck. Conversely, Dr. John Hendren Bell represented the interests of the colony after the death of Albert.
Lastly, another critical participant is Buck‘s lawyer, Irving Whitehead. Irving Whitehead’s failure to defend his client played a role in the outcome of the case in all the three levels of the U.S. court system. First, he did not dispute the evidence presented before the judges. Secondly, he did not call witnesses in defense of his clients. For example, in his appeal, Irving Whitehead presented his arguments in an eight-page long document against the colony’s 44-page response. Therefore, in every aspect, Irving Whitehead seemed compromised from the start and was not necessarily working for the interest of his client.
Reactions
According to Wolfe (November 4, 2015), the press hailed the ruling with the Daily Progress terming Holmes opinion as a genuine classic. Equally, the Daily Progress press hailed the decision as progressive. On the other hand, the Time Magazine applauded the decision and described those opposed to the ruling and eugenics as sentimentalists. Besides the press, other U.S. states followed in the footsteps of the State of Virginia and enacted sterilization statutes. In a decade, about seven states across the U.S. and Puerto Rico passed and ratified the law legalizing the sterilization of individuals considered unfit to procreate. Over the years, the practice grew in prominence with over 28,000 Americans being subjected to this cruelty within ten years. However, the sterilization law was eventually outlawed in 1942 during Sinner v Oklahoma case by the U.S. Supreme Court. The judges held that the practice was punitive and inhumane.
The detractors of sterilization law included the philosopher Russell who argued that the law was a misrepresentation of the morality of the U.S. community disguised as science. Similar sentiments were echoed by Pope Pius XI who argued that eugenics was against a higher order ordained by God. Others who were against the ruling are historians who determined that neither Carrie Buck nor her Vivian Dobbs, her daughter had a mental illness. In essence, the case was based on falsehood and false diagnosis. For example, Paul Lombard observed Carrie’s and her daughter’s report cards and concluded that there was little to suggest mental deficiencies in both the mother and the child (Lombardo, 2008). Further, he found that Carrie’s pregnancy was not as a result of promiscuity, but rather an eventuality of rape.
Historical Context
According to Michael and Cruz (n.d.), by the end of the 19th century, the scientific community and the public, in general, began to contemplate the possibility of improving the chances of survival of the human race through selective breeding. This thought was inspired by Charles Darwin’s theory of evolution, which was gaining popularity in society. Out of this aspiration, the eugenics movement was imitated by Sir Francis Galton (Berson & Cruz, n.d.). As a result, individuals who were considered healthy (physically and mentally) were encouraged to sire more children, while those with undesirable characteristics were discouraged from having many children. Primarily, the proponents of this proposal argued that this reality could be achieved in several ways. For example, they suggested marriage restrictions, particularly across the racial divide. Also, they proposed institutional segregation as well as forced sterilizations.
In the U.S. context, Antonios and Raup (2012) say that the compulsory sterilization movement grew in popularity in the 1890s as the political class intensified the debate about eugenics. Also, most states in the U.S. started to replace castration with sterilization operations, which was considered less brutal as compared to previous forms of mutilation. Primarily, the eugenics movement argued that sterilization was necessary to rid the society of hereditary defects, which tends to weaken the nation over time. Extremist eugenics advocated for harsh methods, such as immigration restrictions, sterilization, and restrictions of interracial marriages. On the other hand, positive eugenics discouraged reproduction among individuals who were considered socially inferior and encouraged breeding among individuals with superior hereditary factors.
This debate persistent for an extended period until compulsory sterilization was legalized. According to Antonios and Raup (2012), twelve U.S. states had ratified and adopted statutes authorizing compulsory sterilization by 1914. Nonetheless, these laws were either regularly challenged in courts of law or weakly enforced. In Virginia, the mandatory sterilization law was ratified on March 20th, 1924 as Virginia Eugenical Sterilization Act. The act provided that the state institutions were at liberty to sterilize patients they deemed mentally unstable, epileptic, or idiotic. In the case given, Priddy sought to validate the Act by fronting a test case for judicial review. This fact explains why, Priddy sponsored the Buck v Priddy case, which was later introduced in the U.S. Supreme Court as Buck v Bell to test the constitutionality of the legislation.
Regarding the debates, tensions, and cultural wars that existed in the United States at the time, there was a common understanding that mental illness and criminal tendencies were hereditary. And, in most cases, these traits were associated with African Americans and American Indians who the eugenicists believed that they suffered from inferior genes. Likewise, similar sentiments were echoed regarding the poor, criminals, and alcoholics as well as prostitutes. This argument gave scientific credibility to the prominence of the white supremacy theory, and, subsequently, inspired Virginia’s Act to Preserve Racial Integrity of 1924. In essence, while there were no direct links between crime and heredity, the associations between the two factors were forced based on racial discrimination. Therefore, the law on compulsory sterilization was primarily aimed at upholding the purity of the white race by eliminating minority groups, which were considered inferior.
According to Cynkar (1981), Supreme Court decisions exemplify the complex historical processes that define the United States political and legal principles. The ruling in Buck v Bell case demonstrated the implicit process through which American values are promulgated in constitutional adjudication. Also, it exemplified prejudice on the part of the judges relative to fellow men. From a social perspective, the administration of the case was based on falsehood a factor that cannot be tolerated in the current democratic space in the country. In this way, the case demonstrates the significance of the ruling in American history in the sense that there is a wide rift in moral values between the present and the past. Also, the differences between the present and past in the dispensation of justice showcases the inherent problems in the principle of fundamental law. Equally, it brings into questions the meaning of justice. Primarily, justice or principle of fundamental law was mainly founded on unanchored reason or sentiment shared by the Judges. Therefore, Buck v Bell is an example of a force that threatened the peaceful coexistence of American society.
From an economic perspective, the case portrayed the implication of the socioeconomic status of individuals on their wellbeing and rank in the social class. Mostly, individuals who were sterilized were either poor or from working-class backgrounds. Carrie Buck serves as an excellent example to illustrate this point because her crime was that of being poor since she was white. In contrast to Carrie Buck, other white patients from wealthy families were not committed to state facilities but rather cared for at home and private institutions. As a result, they were inaccessible and rarely subjected to sterilization. The same case applies to African Americans who were seldom admitted to public mental hospitals due to their beliefs regarding mental health and illness. This fact indicates that the legislation was not ill-convinced and meant only to target the disadvantaged and vulnerable population in the society.
Politically, the case demonstrated insensitivity on the part of the political class when considering legislation for enactment. Also, it showcases deficiency in political representation whereby the interests of a section of the population are not adequately represented. Furthermore, the enactment of the compulsory sterilization law portrays a divide nation that does not pay attention to the minorities in the community. Essentially, issues of poverty can be eliminated through sound economic policies and not necessarily by elimination of individuals considered to be poor. Therefore, the case highlights deficiency in post World War II America. Today, Buck v Bell case serves as a critical guide for decision making among the political class, which is increasingly becoming sensitive to issues affecting all Americans regardless of their population size.
The Implications of the Court’s Ruling
The ruling had significant implications on the U.S. judicial system and constitutionality. First, the successful prosecution of the case by the state of Virginia in the U.S Supreme Court encouraged other states across the country to enforce the law. For other states, Buck v Bell case inspired respective legislative assemblies to enact the sterilization laws that mirrored those in Virginia in a move that was aimed at strengthening the existing sterilization statutes. Besides, the affirmation of the constitutionality of the compulsory sterilization law, the case empowered physicians to carry out sterilization with zero fear for prosecution. Similarly, it led to an increase in the number of sterilizations across the country. For example, before the act was repealed in 1974, over 8,300 Virginians had been subjected to forceful sterilization. Thus, the ruling inspired a wave of abuse, which led to massive violations of people’s rights to equal protection.
Lastly, the case tarnished the institutional integrity of the Virginian court system and the U.S Supreme Court in the sense that they okay the violations of people’s rights to equal protection against the spirit of the framers of the constitution. Subsequent research, after the Buck v Bell landmark ruling, indicated that the case was prosecuted based on falsehood and Carrie Buck and her daughter were of sound mind. Primarily, while the court system is supposed to enforce the provisions of the law, it must be impartial regardless of the specifics of the lawsuit. Therefore, the U.S. court system must live with the shame that the over 36,000 Americans who were involuntarily sterilized were victims of the failure or the court’s abdication of the case. Primarily, while the
Conclusion
Overall, it is unfortunate that Carrie Buck was subjected to such cruelty when she was supposed to enjoy immunity under the Fourteenth Amendments to the U.S. Constitution. Nonetheless, the case was an eye-opener to the justice system regarding the need for carrying out due diligence is evaluating evidence at hand, before prosecuting a case. I tend to believe the unjust ruling was manifestations of the prejudice judges have over they follow men and not necessarily a dispensation of their duty. Equally, the case exposes the rot in the political system, which segregates the population based on their color, race, and socioeconomic status. Nonetheless, while the court redeemed its image, it must forever bear the shame of subjecting over 36,000 Americans to untold suffering simply because the judges were partial in their ruling.
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References
Antonios, N., & Raup, C. (2012). Buck v. Bell (1927). The Embryo Project Encyclopedia. Retrieved from https://embryo.asu.edu/pages/buck-v-bell-1927.
Berson, M., & Cruz, B. Eugenics past and present remembering Buck v. Bell. Retrieved from http://www.socialstudies.org/sites/default/files/publications/se/6505/650507.html.
Buck v. Bell, 274 U.S. 200, (1927).
Cynkar, R. J. (1981). Buck v. Bell: Felt necessities v. fundamental values. Columbia Law Review, 81, 1418.
Facing History and Ourselves. (2019). The Supreme Court and the sterilization of Carrie Buck. Facing History and Ourselves. Retrieved from https://www.facinghistory.org/resource-library/supreme-court-and-sterilization-carrie-buck.
Lombardo, P. A. (2008). Three generations, no imbeciles: Eugenics, the Supreme Court, and Buck v. Bell. JHU Press.
Wolfe, B. (November 4, 2015). Buck v. Bell (1927). In encyclopaedia Virginia. Retrieved from https://www.encyclopediavirginia.org/buck_v_bell_1927.
Kastellec, J. P. (2011). Hierarchical and collegial politics on the US courts of appeals. The Journal of Politics, 73(2), 345-361.