Book Review
Three Generations, No Imbeciles: Eugenics, the Supreme Court, and Buck v. Bell
N Engl J Med 2008; 359:2402-2403November 27, 2008
- Article
Three Generations, No Imbeciles: Eugenics, the Supreme Court, and Buck v. Bell
By Paul A. Lombardo. 365 pp., illustrated. Baltimore, Johns Hopkins University Press, 2008. $29.95. ISBN: 978-0-8018-9010-9Paul Lombardo's book is an authoritative history of the U.S. Supreme Court's infamous decision, Buck v. Bell (1927), which held that Virginia's mandatory sterilization law did not violate Carrie Buck's constitutionally protected rights. Lombardo, an attorney and a historian who has played an important role in soliciting apologies for eugenics laws, chronicles the social, scientific, and legal background of the case, follows the lives of key players, and examines the effect that the case had on law and public opinion in the United States and in Europe. The book is lucidly written, well researched, thorough, and provocative.
Buck v. Bell was decided at the pinnacle of the U.S. eugenics movement. Many states had passed laws that allowed physicians to sterilize residents of state mental institutions. State courts had found that some of the laws were unconstitutional because they violated procedural rights to due process or equal protection under the law. Eugenicists had developed a model sterilization law that was designed to meet these procedural requirements, and in 1924 Virginia adopted it, virtually word for word. Leaders of the eugenics movement wanted a test case for this new law so that other states could be confident that the courts would support similar laws. Carrie Buck was chosen as a test case. To demonstrate that Buck's mental disability was inherited, doctors and social workers gathered evidence about her mental abilities, as well as those of her mother, Emma Buck, and her 8-month-old daughter, Vivian Buck. A state board determined that Carrie Buck met the legal and medical requirements for sterilization. An appeal failed, and a lawsuit to stop the sterilization was heard in the U.S. Supreme Court. In ruling against Carrie Buck, Associate Justice Oliver Wendell Holmes, Jr., penned the phrase, “three generations of imbeciles are enough,” to justify the state's authority to sterilize mentally disabled people for the protection of the public welfare.
Carrie Buck and Emma Buck, 1924. Lombardo's book contains many disturbing revelations about Buck v. Bell, its context, and its consequences. First, the defense mounted by Buck's lawyer, Irving Whitehead, was a sham — he did not seriously challenge any of the claims the defense made, and he frequently helped to reinforce their case. Second, many of the judges involved in the case, including Holmes, were eugenicists. Third, the decision was based on cooked-up facts. None of the three Bucks were “imbeciles” — they could all read and write, and they all attended school. The main reason Buck had been admitted to a state institution was that her foster parents did not want to deal with her sexual “immorality.” Fourth, Carrie Buck's child was the product of rape — not of promiscuity. Fifth, although most states have repealed or changed their sterilization laws, the U.S. Supreme Court has never overturned Buck v. Bell, even though it had a chance to do so in Skinner v. Oklahoma (1942). Finally, in the years that followed the decision, more than a dozen other states and several European nations adopted eugenics laws. More than 60,000 Americans and 400,000 Germans were sterilized under these laws.
As biomedical researchers continue to learn more about the genetic basis of complex behavioral traits, it is important to remember the lessons of Buck v. Bell. The eugenics movement may seem to be a chapter from the distant past, but many of the objectives of those in the movement, such as the promotion of public health, the furthering of human excellence, and the search for scientific solutions to social problems, sprang from ideas that still have considerable influence today. Three Generations, No Imbeciles is a must read for anyone who wants to understand the historical context of Buck v. Bell and its implications for ethics, law, and public policy.
David B. Resnik, J.D., Ph.D.
National Institute of Environmental Health Sciences,, National Institutes of Health, Research Triangle Park, NC 27709
resnikd@niehs.nih. gov This review does not represent the views of the National Institute of Environmental Health Sciences or the National Institutes of Health.
