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Buck v. Bell, Supreme Court of Appeals of Virginia, Brief for Appellee, September 1925


CONTENT WARNING: Materials in the Library of Virginia's collections contain historical terms, phrases, and images that are offensive to modern readers. These include demeaning and dehumanizing references to race, ethinicity, and nationality; enslaved or free status; physical and mental ability; religion; sex; and sexual orientation and gender identity.
The Progressive Movement was rooted in the idea that the government should improve the lives of its citizens. Most of the accomplishments, including the 40-hour work week, women’s suffrage, and direct election of senators, benefited society; however, some of these efforts may have been misguided, like Prohibition. The dark side of the Progressive Era was seen in the eugenics movement, which argued that people with “inferior” genes should be stopped from breeding. Eugenicists believed that the scientific method of cross breeding crops and animals should be applied to humans. Eugenicists believed that certain traits, like insanity, criminal tendencies, shiftlessness, promiscuity, and “feeble-mindedness” were hereditary, and that these traits should be eliminated from the human race. Virginia and other states started to add eugenics criteria in marriage applications, requiring that applicants swear that they were not “a habitual criminal, idiot, imbecile, hereditary epileptic, or insane.” Soon after, states started passing sterilization laws that allowed institutions to remove the reproductive capacities of its inmates. By 1940, twenty eight states had authorized compulsory sterilization. Virginia started its sterilization program in 1916, and it was codified into law with the Virginia Sterilization Act of 1924.    

Carrie Buck was born in 1906 in Charlottesville and was raised by foster parents. Her biological mother, Emma Buck, was identified as a “low grade moron,” and was committed to the Virginia State Colony for Epileptics and Feeble-Minded.  In 1924, Carrie had a baby out of wedlock, saying that she had been raped by her foster family’s nephew. However, her foster parents claimed that she had invited the contact due to her promiscuity, and that this wanton behavior offered further proof to have her committed to the Colony. The superintendent of the Virginia State Colony for Epileptics and Feeble-Minded, Dr. Albert Priddy, was a dedicated eugenicist, and selected Carrie Buck as a test case to make sure the Virginia law was constitutional. This excerpt of Dr. Priddy’s testimony is from the brief prepared for the Supreme Court of Appeals of Virginia in 1925. The case was appealed all the way to the Supreme Court, where the sterilization law was confirmed as constitutional: Chief Justice Oliver Wendell Holmes declared that “three generations of imbeciles are enough.” Buck was sterilized in 1927. During the Nuremberg trials after WWII, several Nazis on trial based their defense on the prevalence of sterilization in the United States and the Supreme Court decision in Bell v. Buck. Over 60,000 Americans, including 8,300 Virginians, were sterilized by the time the eugenics laws were repealed in the 1970’s.  

Citation: Buck v. Bell, Supreme Court of Appeals of Virginia, Brief for Appellee, September Term 1925, Records of Western State Hospital, 1825-2000, Box 88, Folder 27, State Government Records Collection, The Library of Virginia, Richmond.

Other Sources Used for Context:

Brendan Wolfe, “Buck v. Bell (1927),” Encyclopedia Virginia, 4 November 2015, [viewed 11 December 2017].


VS.9, USII.4, CE.10, VUS.8, VUS.10, GOVT.7, GOVT 8, GOVT.9

Suggested Questions

Up for Debate: In your opinion, what are the limits of a government’s obligation to its mentally challenged citizens? Specifically, to what extent do you believe a government can intervene regarding mentally challenged citizens (such as sterilizing citizens)?

Cross-curricular Connections: Gregor Mendel’s experiments with genetics were rediscovered in 1900. How might this have supported the development of eugenics?