Carrie Buck

Carrie Buck (born July 2, 1906?, Charlottesville, Virginia, U.S.—died January 28, 1983, Waynesboro, Virginia) was an American woman who was the plaintiff in the case of Buck v. Bell (1927), in which the U.S. Supreme Court upheld the constitutionality of compulsory eugenics-based sterilization laws.

When Buck was three years old, her mother was institutionalized after being found “feebleminded” and “sexually promiscuous”; Buck’s father had reportedly abandoned the family. Buck subsequently lived with foster parents John and Alice Dobbs. At age 17 she became pregnant and accused the Dobbses’s nephew of having raped her. The Dobbses then petitioned to have her institutionalized, and, after she received a diagnosis similar to that of her mother, Buck was sent to the State Colony for Epileptics and Feebleminded. After she gave birth in 1924, the institute’s superintendent, Albert Sidney Priddy (later replaced by John Hendren Bell), chose Buck as the first person to be sterilized under a new Virginia law that allowed for the forced sterilization of those in state institutions who were “afflicted with hereditary forms of insanity that are recurrent, idiocy, imbecility, feeblemindedness, or epilepsy.”

Buck protested the procedure, and the law’s consitutionality was challenged. In testimony before a circuit court, various experts supported the eugenics-based law, claiming that “feeblemindedness runs in families.” In addition, several health care workers described Buck as “feebleminded” and her infant daughter as being “below average” and “not quite normal.” In 1925 the court found the law constitutional and determined that Buck was a suitable candidate for sterilization, calling her a “potential parent of socially inadequate offspring.” After the Virginia Supreme Court of Appeals affirmed the ruling, Buck v. Bell was argued before the U.S. Supreme Court in 1927. The court, in an 8–1 decision, upheld the law’s constitutionality. In the majority opinion, Justice Oliver Wendell Holmes, Jr., wrote that “three generations of imbeciles are enough.” Buck was sterilized in 1927, and shortly therafter she was released from the institution.

Buck later married William Eagle and, after his death, Charles Detamore. Her only child, Vivian, was raised by the Dobbs family until she died of an intestinal disorder in 1932; a year earlier she had been on her school’s honour roll. Buck’s younger sister, Doris Buck Figgins, was also sterilized as a teenager. The Virginia sterilization law was repealed in 1974.