Court: Supreme Court of the United States; June 1, 1942; Federal Supreme Court; Federal Appellate Court
Mr. Justice Douglas delivered the Court's opinion addressing a significant human rights issue regarding Oklahoma's Habitual Criminal Sterilization Act, which permits the sterilization of individuals deemed "habitual criminals." The Act applies to those convicted of multiple felonies involving moral turpitude, with procedures allowing for notice, a hearing, and a jury trial. If the jury finds that sterilization poses no health risks, the court is mandated to order the procedure. The petitioner, who had multiple felony convictions, challenged the Act's constitutionality under the Fourteenth Amendment. The Oklahoma Supreme Court upheld the sterilization order, leading to further scrutiny by the U.S. Supreme Court.
Key constitutional challenges included claims of inadequate due process, lack of scientific basis for the Act, and arguments that it constitutes cruel and unusual punishment. However, the Court concentrated on the Act's violation of the equal protection clause of the Fourteenth Amendment. The opinion highlighted specific inequalities, such as the classification of felonies, indicating that the Act fails to provide equal treatment under the law.
Embezzlement of property valued over $20 constitutes a felony, applicable to both employees (e.g., clerks) and outsiders committing theft. However, a clerk is exempt from penalties under the Act, regardless of the frequency or amount of embezzlement. In contrast, a stranger convicted three times for theft may face sterilization. Individuals stealing chickens from a coop are also guilty of a felony and subject to sterilization after three convictions. If a bailee fraudulently appropriates property, it is classified as embezzlement, and the individual cannot be sterilized, regardless of repeated offenses. Both embezzlement and larceny share intrinsic similarities but are differentiated by the timing of fraudulent intent. Legislation that allows sterilization raises constitutional concerns, particularly regarding the equal protection clause of the Fourteenth Amendment. The legislation must avoid arbitrary discrimination based on the nature of offenses, as sterilizing repeat offenders of larceny while exempting embezzlers constitutes unjust discrimination. The argument underscores the critical civil rights implications of sterilization laws, emphasizing the need for careful scrutiny to prevent invidious discrimination against individuals or groups.
Oklahoma distinguishes between larceny by fraud and embezzlement based on when the intent to convert property arises. The legal distinctions between these crimes have no relevance to eugenics or the inheritability of criminal traits. Under Oklahoma law, larceny and embezzlement carry equivalent penalties; however, sterilization laws treat these offenses differently. The equal protection clause is called into question when such arbitrary classifications are allowed. The case references Buck v. Bell, which upheld a Virginia sterilization statute for feeble-minded individuals, arguing that it served a purpose in managing institutional populations. In contrast, embezzlers are not confined, raising concerns about fairness in classification for sterilization under Oklahoma law. The Act in question includes a broad severability clause, yet the Oklahoma Supreme Court upheld it without addressing this clause, leaving unresolved discrimination issues. The potential impact of severability on constitutional objections remains uncertain, specifically regarding which criminals could be subject to sterilization. The ruling is reversed, indicating a need for further adjudication on these matters by the Oklahoma court.
