Buck v. Bell
Docket: 292
Court: Supreme Court of the United States; May 2, 1927; Federal Supreme Court; Federal Appellate Court
In the case of Buck v. Bell, the U.S. Supreme Court reviewed a judgment from the Virginia Supreme Court of Appeals regarding the sterilization of Carrie Buck, a feeble-minded woman. The Circuit Court of Amherst County had ordered the superintendent of the State Colony for Epileptics and Feeble Minded to perform a salpingectomy on Buck to render her sterile, based on a Virginia statute enacted in 1924 that permitted sterilization of individuals deemed mentally defective. The statute aimed to promote public health by preventing procreation among those with hereditary mental disabilities, asserting that such individuals could be safely discharged from institutions if sterilized. The sterilization process required the superintendent to petition a special board, providing evidence and grounds for the operation. Notification was mandated for the inmate and their guardian, with provisions for minors to notify their parents as well. The board's decision could be appealed to the Circuit Court, which reviewed the case and could affirm or reverse the board's order. Further appeals could be made to the Supreme Court of Appeals, which would examine the Circuit Court's record. Buck's appeal contended that the statute violated the Fourteenth Amendment by denying her due process and equal protection under the law. The case highlights the legal and ethical implications of eugenics policies in early 20th-century America, particularly regarding the rights of individuals with disabilities. Patient rights have been rigorously upheld throughout the legal proceedings, and all actions were taken in strict accordance with the law, ensuring due process for the plaintiff. The challenge presented is not procedural but relates to the substantive law, arguing that the order for sterilization cannot be justified under any circumstances, particularly on the existing grounds. The court found that Carrie Buck is likely to bear socially inadequate offspring and that her sterilization would not harm her health but rather benefit her welfare and society. Given the legislative context and the court's specific findings, it cannot be legally asserted that the grounds for sterilization do not exist; if they do, they warrant the action taken. The text further argues that public welfare may necessitate sacrifices from those deemed unfit to prevent societal issues. It draws parallels between compulsory vaccination and sterilization, suggesting both serve the public good. The dissenting opinion highlights concerns about the selective application of such laws, noting the need for equitable treatment for all similarly situated individuals. The court ultimately affirmed the judgment, with Justice Butler dissenting.