In 1927, the United States Supreme Court ruled 8–1 that the state of Virginia could sterilize a 20-year-old woman against her will. Justice Oliver Wendell Holmes Jr. — Civil War veteran, giant of American law — wrote the opinion. It runs barely five paragraphs, and it contains the most notorious sentence in the Court's history:

"Three generations of imbeciles are enough."

The woman was Carrie Buck. Almost everything the Court believed about her was wrong, and the people who put her in front of the Court knew it.

Where Carrie Buck came from

Carrie was born in Charlottesville, Virginia, in 1906. Her mother, Emma Buck, was poor and widowed, and in 1920 Emma was committed to the Virginia State Colony for Epileptics and Feebleminded outside Lynchburg — the fate Virginia reserved for poor women it found inconvenient.

Carrie was placed with a foster family, John and Alice Dobbs. She went to school, where her records describe an ordinary student — she was promoted with her class and her teachers noted "deportment and lessons very good." The Dobbses pulled her out after sixth grade to do housework.

In 1923, at seventeen, Carrie was raped by Alice Dobbs's nephew. She became pregnant. The Dobbs family's response was to have her declared feebleminded and "morally delinquent" and committed to the same Colony that held her mother. Her daughter, Vivian, was born in March 1924 and kept by the Dobbs family.

The commitment solved two problems at once: it removed the family's embarrassment, and it delivered to the Colony exactly what its superintendent had been waiting for.

Why her case went to the Supreme Court

Virginia had passed a eugenical sterilization law in March 1924, drafted by attorney Aubrey Strode. The Colony's superintendent, Dr. Albert Priddy, had been sterilizing women for years under thin legal cover and wanted a statute that could survive a court challenge. What the law needed was a test case — a patient who would be sterilized, whose case would be appealed, and whose appeal would lose, establishing the law once and for all.

Carrie was chosen. Seventeen years old at commitment, a mother, daughter of a committed mother: three generations, if you squinted.

Here is the part the novel takes its title from: nobody had to lie. The hearing was real. The appeal was real. Carrie had a lawyer, Irving Whitehead — a founding board member of the very Colony that wanted her sterilized, a close friend of Strode's, paid by the Colony. He called no witnesses. He challenged no evidence. He was, in every functional sense, hired to lose, and he performed exactly as hired.

The evidence for Vivian's deficiency — the third generation — was a social worker's impression of a seven-month-old baby: "There is a look about it that is not quite normal."

What Holmes wrote

The case reached the Supreme Court as Buck v. Bell (Priddy had died; Dr. John Bell replaced him as defendant). On May 2, 1927, the Court upheld Virginia's law 8–1. Holmes wrote that the principle sustaining compulsory vaccination was "broad enough to cover cutting the Fallopian tubes," and that society could prevent "those who are manifestly unfit from continuing their kind." Only Justice Pierce Butler dissented, without writing a word.

Carrie Buck was sterilized at the Colony on October 19, 1927.

What the three generations actually were

  • Emma Buck died in the Colony in 1944, having spent the last 24 years of her life inside it.
  • Carrie was paroled after her sterilization, worked for the rest of her life, married twice, sang in a church choir, and read the newspaper daily — a literate, competent woman, which surprised the researchers who tracked her down decades later. She died in 1983 in Waynesboro, Virginia.
  • Vivian — the "not quite normal" baby — went to school in Charlottesville and in 1931 was placed on her school's honor roll. She died the next year, at eight, of complications from measles.

Carrie's younger sister Doris was also sterilized at the Colony. She was told the operation was an appendectomy. She and her husband tried for children for decades; she learned the truth in 1980.

What happened after

More than thirty American states operated sterilization programs, and roughly 70,000 Americans were sterilized under them — the majority poor women. Virginia alone sterilized about 8,000 people and did not repeal its law's practice until the 1970s. The state formally apologized in 2002.

And the case itself? Buck v. Bell was never overturned. It was narrowed, discredited, and abandoned in practice — but the precedent still stands.

Sixteen years after Holmes wrote his sentence, defense lawyers at Nuremberg read American sterilization law aloud in open court, on behalf of German doctors. That part of the story — how a Virginia courtroom ended up in a Nazi legal defense — is the subject of the companion piece to this one.

Sources and further reading

The definitive accounts are Paul A. Lombardo's Three Generations, No Imbeciles: Eugenics, the Supreme Court, and Buck v. Bell — Lombardo located Carrie's school records and interviewed her before her death — and Adam Cohen's Imbeciles: The Supreme Court, American Eugenics, and the Sterilization of Carrie Buck. Both are readable, meticulous, and hard to put down for all the wrong reasons.