Buck vs. Bell

A state statute authorizing the compulsory sterilization of the "feeble-minded" in state institutions does not violate the Due Process or Equal Protection Clauses of the Fourteenth Amendment, as the public welfare supporting such eugenic measures outweighs the individual's liberty interest.

The early 20th century in the United States saw the rise of the eugenics movement, which promoted the idea of improving the human race through selective breeding. Many states passed laws permitting the forced sterilization of individuals deemed mentally ill, "feeble-minded," or otherwise "unfit." Virginia's 1924 "Eugenical Sterilization Act" was one such law.

• Filed in the Circuit Court of Amherst County, Virginia.
• The Circuit Court upheld the sterilization order.
• The Supreme Court of Appeals of Virginia affirmed the Circuit Court's judgment.
• Elevated to the U.S. Supreme Court via writ of error.

• Carrie Buck was an 18-year-old white woman committed to the Virginia State Colony for Epileptics and Feeble Minded.
• Her mother was also a patient at the same institution.
• Buck had given birth to an illegitimate child, who was also deemed "feeble-minded."
• The superintendent of the colony petitioned for Buck's sterilization (salpingectomy) under the 1924 Virginia statute.
• After the required procedural safeguards (notice, hearing before a board, appeal to the Circuit Court), the order for sterilization was issued.

• The Virginia sterilization statute violated the Due Process Clause of the Fourteenth Amendment by depriving her of a fundamental liberty interest (bodily integrity) without sufficient justification.
• The statute violated the Equal Protection Clause because it applied only to inmates of state institutions and not to "feeble-minded" persons at large.

• The statute was a valid exercise of the state's police power to protect public health and welfare.
• The law's procedures provided all the due process required.
• The classification (institutionalized individuals) was reasonable because the state had direct control over them and could assess their condition, thus satisfying equal protection.

• Procedural Issues: N/A. The petitioner conceded the procedural safeguards were adequate.
• Substantive Issues:
  • Whether the Virginia sterilization statute violated the Due Process Clause of the Fourteenth Amendment.
  • Whether the Virginia sterilization statute violated the Equal Protection Clause of the Fourteenth Amendment.

• Procedural: N/A.
• Substantive: The SC affirmed the judgment of the Virginia Supreme Court of Appeals.
• Due Process: The SC held the statute was a valid exercise of police power. The state's interest in preventing the propagation of those who would "sap the strength of the state" was a legitimate public welfare objective that justified the intrusion on individual liberty. The SC analogized to compulsory vaccination (Jacobson v. Massachusetts).
• Equal Protection: The SC rejected the argument that the law was under-inclusive. It held the state could address the problem "so far and so fast as its means allow," and that applying the law to institutionalized persons was a reasonable first step.

• Police Power — The inherent power of a state to enact laws to protect public health, safety, morals, and general welfare. The SC held that eugenic sterilization fell within this power.
• Rational Basis Review — The implicit standard of review applied. The SC found the state had a legitimate interest (preventing "incompetence") and that the law was rationally related to that interest (sterilizing those in state care deemed likely to produce "socially inadequate offspring").

• "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."
• "Three generations of imbeciles are enough."

• Jacobson v. Massachusetts, 197 U.S. 11 (1905) — Cited as controlling precedent for the principle that individual liberty may be constrained under the police power for public health and safety (compulsory vaccination). The SC reasoned this principle was "broad enough to cover cutting the Fallopian tubes."

• U.S. Constitution, Amendment XIV, Section 1 (Due Process Clause) — The central constitutional provision at issue; the SC found no deprivation of liberty without due process.
• U.S. Constitution, Amendment XIV, Section 1 (Equal Protection Clause) — The SC found the statute's classification did not deny equal protection.

• Justice Butler (Dissenting) — Filed a one-sentence dissent without recorded opinion.