Three Generations, No Imbeciles: Eugenics, the Supreme Court, and Buck V. Bell by Paul A. Lombardo

From the Publisher

"Three generations of imbeciles are enough." Few lines from Supreme Court opinions are as memorable as this declaration by Justice Oliver Wendell Holmes Jr. in the landmark 1927 case Buck v. Bell. The ruling allowed states to forcibly sterilize residents in order to prevent "feebleminded and socially inadequate" people from having children. It is the only time the Supreme Court endorsed surgery as a tool of government policy. Paul Lombardo's startling narrative exposes the Buck case's fraudulent roots.

In 1924 Carrie Buck — involuntarily institutionalized by the State of Virginia after she was raped and impregnated — challenged the state's plan to sterilize her. Having already judged her mother and daughter mentally deficient, Virginia wanted to make Buck the first person sterilized under a new law designed to prevent hereditarily "defective" people from reproducing. Lombardo's more than twenty-five years of research and his own interview with Buck before she died demonstrate conclusively that she was destined to lose the case before it had even begun. Neither Carrie Buck nor her mother and daughter were the "imbeciles" condemned in the Holmes opinion. Her lawyer — a founder of the institution where she was held — never challenged Virginia's arguments and called no witnesses on Buck's behalf. And judges who heard her case, from state courts up to the U.S. Supreme Court, sympathized with the eugenics movement. Virginia had Carrie Buck sterilized shortly after the 1927 decision.

Though Buck set the stage for more than sixty thousand involuntary sterilizations in the United States and was cited at the Nuremberg trials in defense of Nazi sterilizationexperiments, it has never been overturned. Three Generations, No Imbeciles tracks the notorious case through its history, revealing that it remains a potent symbol of government control of reproduction and a troubling precedent for the human genome era.

Publishers Weekly

Law professor and historian Lombardo does a superb job of revealing, for the first time, all the facts in the infamous Buck v. Bell case of the 1920s, the Supreme Court decision ratifying Virginia's compulsory sterilization of "feebleminded" people. In the majority decision, Chief Justice Oliver Wendell Holmes Jr. called the plaintiffs "manifestly unfit" both mentally and morally, and insisted that "three generations of imbeciles are enough." This decision-which has never been overturned-led to tens of thousands of involuntary sterilizations. Lombardo interviewed the last survivor of the three Buck women who were plaintiffs; turned up indisputable evidence that there was no feeblemindedness in that family; unearthed previously unknown correspondence of Carrie Buck's attorney, who, believing the law to be necessary, mounted a deliberately insufficient defense; and documented the private family tragedy (an incestuous rape and resulting pregnancy) that lay behind the Bucks' encounter with doctors bent on exploring eugenics. His book is a testament to injustice and to ignorance-not that of the Buck women, but rather of powerful doctors, attorneys and Supreme Court justices. 17 b&w photos. (Oct.)

Philip Y. Blue - Library Journal

Lombardo (law, Georgia State Univ.) traces a seminal 1927 Supreme Court case arising from the attempt by authorities in Virginia to force the sterilization of a woman believed to be mentally and socially "insufficient." Lombardo carefully re-creates the trial, which resulted in a ruling formally endorsing the sterilization of Carrie Buck. The case quickly advanced to the U.S. Supreme Court, where the justices ruled that the sterilization law did not violate the Eighth Amendment. Lombardo minces no words in expressing his disdain for the lackluster performance and conflicts of interest of Buck's attorney. Carrie's fate before the Court, argues the author, was partially attributable to social Darwinism as well as the attitude of the Court's chief social arbiter, Oliver Wendell Holmes Jr., that society should not bear the burden of people born without pedigree, status, intelligence, or capacity. Lombardo observes that by the early 1970s medical science had strongly discredited the notion that bad heredity could be interrupted by sterilization, and the entire movement ground to a screeching halt. This original study is highly recommended for academic, public, and law libraries.

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