Carrie Buck
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Carrie Buck (1906-1983) was a plaintiff in the United States Supreme Court case Buck v. Bell 274 U.S. 200 (1927) and was ordered to undergo compulsory sterilization for purportedly being "feeble-minded" as part of the state of Virginia's eugenics program while a patient at Virginia State Colony for Epileptics and Feebleminded. Carrie Buck was born in Charlottesville, Virginia, 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 Dobbses, helping out with chores around the house.
Carrie became pregnant when she was seventeen. Subsequently, on January 23, 1924, Carrie’s foster parents had committed her to the Virginia Colony for Epileptics and Feeble-Minded on the grounds of feeblemindedness, incorrigible behavior and promiscuity. On March 28, 1924, she gave birth to a daughter, Vivian. Since Carrie had been declared mentally incompetent 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 from the Virginia Colony for Epileptics and Feeble-Minded shortly after her sterilization was performed. Carrie eventually wed William Eagle and they remained married for twenty-five years before he passed away. As scholars and reporters visited Carrie it became abundantly clear to everyone that Carrie Buck 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 in 1983; she was buried near her only child, Vivian, in Charlottesville, Virginia.
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[edit] Family
Carrie's mother was Emma Buck, and she had a sister, Doris Buck. Unfortunately, little is known of her mother other than that she was poor, married to Fredrick Buck, who abandoned her, and that she had three children (two daughters and a son). Emma was committed to the Virginia Colony for the Epileptic and the Feeble-minded after being accused of immorality, prostitution, and having syphilis. In a cruel twist of fate, in order to insure that the family did not reproduce, Carrie Buck’s younger sister, Doris, was also sterilized when she was hospitalized for appendicitis but was never told that the operation had been performed. In later years she and her husband tried in vain to have children. She did not discover the reason for her inability to bear children until 1980, and when she was finally told the truth she broke down and cried. They lived in Charlottesville, Virginia.
[edit] Vivian Buck
Carrie had a daughter, Vivian Buck. Vivian Buck was adopted by the Dobbs family, who had also raised Vivian's mother, 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, a month before her death at age eight of "enteric colitis.. Stephen Jay Gould 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 we used to say, 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. Sadly, Vivian died at age eight of due to enteric colitis, an intestinal disease.
[edit] Supreme Court
The legal challenge was likely collusive, brought on behalf of the state to test the legality of the statute. 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. 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.
[edit] 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.
[edit] See also
- Buck v. Bell for more information about the case and its results
- Carrie Buck's Daughter - by Stephen Jay Gould
