Carrie Buck was a plaintiff

Plaintiff

A plaintiff , also known as a claimant or complainant, is the term used in some jurisdictions for the party who initiates a lawsuit before a court...

 in the United States Supreme Court case, Buck v. Bell

Buck v. Bell

Buck v. Bell, , was the United States Supreme Court ruling that upheld a statute instituting compulsory sterilization of the unfit, including the mentally retarded, "for the protection and health of the state." It was largely seen as an endorsement of negative eugenics—the attempt to improve...

, 274 U.S. 200 (1927), and was ordered to undergo compulsory sterilization for purportedly being "feeble-minded

Feeble-minded

The term feeble-minded was used from the late nineteenth century in Great Britain, Europe and the United States to refer to a specific type of "mental deficiency". At the time, mental deficiency was an umbrella term, which encompassed all degrees of educational and social deficiency...

." The surgery was carried out while Buck was an inmate of the Virginia State Colony for Epileptics and Feebleminded

Virginia State Colony for Epileptics and Feebleminded

The Virginia State Colony for Epileptics and Feebleminded opened in 1910 as the Virginia State Colony for Epileptics near Lynchburg, Virginia. It was authorized by a 1906 bill written by eugenicist and social welfare advocate Aubrey Strode, in collaboration with eugenicists Albert Priddy and...

 under the authority of the Racial Integrity Act of 1924

Racial Integrity Act of 1924

On March 20, 1924 the Virginia General Assembly passed two laws that had arisen out of contemporary concerns about eugenics and race: SB 219, entitled "The Racial Integrity Act" and SB 281, "An ACT to provide for the sexual sterilization of inmates of State institutions in certain cases",...

, part of the state of Virginia

Virginia

The Commonwealth of Virginia , is a U.S. state on the Atlantic Coast of the Southern United States. Virginia is nicknamed the "Old Dominion" and sometimes the "Mother of Presidents" after the eight U.S. presidents born there...

's eugenics

Eugenics

Eugenics is the "applied science or the bio-social movement which advocates the use of practices aimed at improving the genetic composition of a population", usually referring to human populations. The origins of the concept of eugenics began with certain interpretations of Mendelian inheritance,...

 program. Carrie Buck was born in Charlottesville, Virginia

Charlottesville, Virginia

Charlottesville is an independent city geographically surrounded by but separate from Albemarle County in the Commonwealth of Virginia, United States, and named after Charlotte of Mecklenburg-Strelitz, the queen consort of King George III of the United Kingdom.The official population estimate for...

, to Emma Buck. After her birth, Carrie was placed with foster parents, John and Alice Dobbs. She attended public school until the sixth grade and then continued to live with the Dobbs, helping out with chores around the house.

Carrie became pregnant when she was seventeen as a result of being raped. Subsequently, on January 23, 1924, Carrie’s foster parents had committed

Involuntary commitment

Involuntary commitment or civil commitment is a legal process through which an individual with symptoms of severe mental illness is court-ordered into treatment in a hospital or in the community ....

 her to the Virginia Colony for Epileptics and Feeble-Minded on the grounds of feeblemindedness, incorrigible behavior and promiscuity

Promiscuity

In humans, promiscuity refers to less discriminating casual sex with many sexual partners. The term carries a moral or religious judgement and is viewed in the context of the mainstream social ideal for sexual activity to take place within exclusive committed relationships...

. On March 28, 1924, she gave birth to a daughter, Vivian. Since Carrie had been declared mentally incompetent

Competence (law)

In American law, competence concerns the mental capacity of an individual to participate in legal proceedings. Defendants that do not possess sufficient "competence" are usually excluded from criminal prosecution, while witnesses found not to possess requisite competence cannot testify...

 to raise her child, her former foster parents adopted the baby. Her commitment may have been due to the family's embarrassment since Carrie's pregnancy was the result of being raped by the Dobbses’ nephew.

Carrie Buck was paroled shortly after her sterilization was performed, eventually married William Eagle, and they remained married for twenty-five years before he died. Reporters and researchers that visited Buck later in life claimed she was a woman of normal intelligence. Later in life, she expressed regret that she had been unable to have additional children. Carrie Buck died alone in a nursing home

Nursing home

A nursing home, convalescent home, skilled nursing unit , care home, rest home, or old people's home provides a type of care of residents: it is a place of residence for people who require constant nursing care and have significant deficiencies with activities of daily living...

 in 1983; she was buried in Charlottesville near her only child, Vivian, who had died at age eight.

Paul A. Lombardo

Paul A. Lombardo

Paul A. Lombardo, JD, Ph.D., is a bioethics and legal scholar. He has extensively studied and written about the U.S. Supreme Court decision in Buck v. Bell. He teaches at both the University of Virginia and Georgia State University...

, a Professor of Law at Georgia State University, spent almost 25 years researching the Buck v. Bell case. He dug through case records and the papers of the lawyers involved in the case. Lombardo eventually found Carrie Buck and was able to interview her shortly before her death. Lombardo has alleged that several people had manufactured evidence to make the state’s case against Carrie Buck, and that Buck was actually of normal intelligence. Professor Lombardo was one of the few people who attended Carrie Buck's funeral.

A historical marker was erected on May 2, 2002, in Charlottesville, Virginia where Carrie Buck was born. At that time, Virginia Governor Mark R. Warner offered the “Commonwealth's sincere apology for Virginia's participation in eugenics.”

Family

Carrie was the first of three children born to Emma Buck; she was soon joined by a sister, Doris Buck, and a brother, Roy Smith. Little is known about Emma Buck other than that she was poor and married to, then abandoned by, Frederick Buck. Emma was committed to the Virginia Colony for the Epileptic and the Feeble-minded after being accused of immorality, prostitution, and having syphilis. In order to ensure that the family did not reproduce, Carrie Buck’s sister Doris was also sterilized when she was hospitalized for appendicitis

Appendicitis

Appendicitis is a condition characterized by inflammation of the appendix. It is classified as a medical emergency and many cases require removal of the inflamed appendix, either by laparotomy or laparoscopy. Untreated, mortality is high, mainly because of the risk of rupture leading to...

, although she was never told that sterilization had been performed. In later years she married and she and her husband attempted to have children; she did not discover the reason for their lack of success until 1980.

Vivian Buck

Carrie had a daughter, Vivian Buck. Vivian Buck was adopted by the Dobbs family, who had also raised Carrie, for a time. Under the name "Vivian Alice Elaine Dobbs," she attended the Venable Public Elementary School of Charlottesville for four terms, from September 1930 until May 1932. Stephen Jay Gould

Stephen Jay Gould

Stephen Jay Gould was an American paleontologist, evolutionary biologist, and historian of science. He was also one of the most influential and widely read writers of popular science of his generation....

 wrote:

She was an [average student], neither particularly outstanding nor much troubled. In those days before grade inflation, when C meant "good, 81-87" (as defined on her report card) rather than barely scraping by, Vivian Dobbs received As and Bs for deportment and Cs for all academic subjects but mathematics (which was always difficult for her, and where she scored a D) during her first term in Grade 1A, from September 1930 to January 1931. She improved during her second term in 1B, meriting an A in deportment, C in mathematics, and B in all other academic subjects; she was on the honor roll in April 1931. Promoted to 2A, she had trouble during the fall term of 1931, failing mathematics and spelling but receiving an A in deportment, B in reading, and C in writing and English. She was "retained in 2A" for the next term -- or "left back" as was formerly said, and scarcely a sign of imbecility as I remember all my buddies who suffered a similar fate. In any case, she again did well in her final term, with B in deportment, reading, and spelling, and C in writing, English, and mathematics during her last month in school. This offspring of "lewd and immoral" women excelled in deportment and performed adequately, although not brilliantly, in her academic subjects.

By all accounts Vivian was of average intelligence, far from feeblemindedness. She died a month later at age eight of "enteric colitis"

Enterocolitis

Enterocolitis is an inflammation of the colon and small intestine. However, most conditions are categorized as one or the other of the following:* Enteritis is the inflammation of the small intestine...

, an intestinal disease.

Supreme Court

The legal challenge was consciously collusive, brought on behalf of the state to test the legality of the statute. John H. Bell, the surgeon who operated on Buck on 19 October, 1927, wrote in his surgical report:

This is the first case operated on under the sterilization law, and the case was carried through the courts of the State and the United States Supreme Court to test the constitutionality of the Virginia act, and an appeal before the Supreme Court for a rehearing recently having been denied.

In an eight to one decision the U.S. Supreme Court found that the Virginia Sterilization Act of 1924 did not violate the U.S. Constitution. Justice Oliver Wendell Holmes made clear that the challenge was not upon the medical procedure involved but on the process of the substantive law. The court was satisfied that the Virginia Sterilization Act complied with the requirements of due process since sterilization could not occur until a proper hearing had occurred at which the patient and a guardian could be present and the patient had the right to appeal the decision. They also found that since the procedure was limited to people housed in state institutions it did not deny the patient equal protection of the law. And finally, since the Virginia Sterilization Act was not a penal statute, the Court held that it did not violate the Eighth Amendment since it is not intended to be punitive. Citing the best interests of the state, Justice Holmes affirmed the value of a law like Virginia's in order to prevent the nation from being "swamped with incompetence." The Court accepted that Carrie and her mother were promiscuous and that the three generations of Bucks’ shared the genetic trait of feeblemindedness. Thus, it was in the state's best interest to have Carrie Buck sterilized. The decision was seen as a major victory for eugenicists.

Supreme Court Justice, Oliver Wendell Holmes, Jr.

Oliver Wendell Holmes, Jr.

Oliver Wendell Holmes, Jr. was an American jurist who served as an Associate Justice of the Supreme Court of the United States from 1902 to 1932...

 wrote in 1927:

We have seen more than once that the public welfare may call upon the best citizens for their lives. It would be strange if it could not call upon those who already sap the strength of the State for these lesser sacrifices, often not felt to be such by those concerned, in order to prevent our being swamped with incompetence. It is better for all the world, if instead of waiting to execute degenerate offspring for crime, or to let them starve for their imbecility, society can prevent those who are manifestly unfit from continuing their kind. The principle that sustains compulsory vaccination is broad enough to cover cutting the Fallopian tubes. Jacobson v. Massachusetts, 197 U.S. 11. Three generations of imbeciles are enough.

Noted Virginia eugenicist Joseph DeJarnette

Joseph DeJarnette

Joseph Spencer DeJarnette was the director of Western State Hospital from 1905 to 1943. He was a vocal proponent of eugenics, specifically, the compulsory sterilization of the mentally ill...

 testified against Buck in the original trial.

Popular culture

The story of Carrie Buck's sterilization and the court case was made into a television drama in 1994, Against Her Will: The Carrie Buck Story with actress Marlee Matlin

Marlee Matlin

Marlee Bethany Matlin is an American actress. She is the only deaf actress to win the Academy Award for Best Actress in a Leading Role, which she won for Children of a Lesser God. Her work in film and television has resulted in a Golden Globe award, with two additional nominations, and four Emmy...

 portraying Buck. "Virginia State Epileptic Colony", a song by the Manic Street Preachers

Manic Street Preachers

Manic Street Preachers are a Welsh alternative rock band, formed in 1986. They are James Dean Bradfield, Nicky Wire, Richey Edwards and Sean Moore. The band are part of the Cardiff music scene, and were at their most prominent during the 1990s...

 on the album Journal for Plague Lovers

Journal for Plague Lovers

Journal for Plague Lovers is the ninth studio album by the alternative rock band Manic Street Preachers. It was released on 18 May 2009, and features posthumous lyrics by Richey Edwards, who vanished on 1 February 1995, and was presumed deceased in 2008. It is the only Manic Street Preachers album...

, addresses the state's programme of eugenics.