Three Generations
In 1905 the Supreme Court upheld a five-dollar vaccination fine and wrote four limits into the opinion. In 1927 it cited that case to uphold the sterilization of Carrie Buck in Virginia, and none of the limits came along. The episode reads both opinions, recounts what later research showed about the Buck family, and traces the decision's survival. An argument from what people cost society is only as good as its limiting principle.
Who's who
- Oliver Wendell Holmes Jr.+3 more episodesJustice who wrote the 8-1 opinion in Buck v. Bell
- John Marshall Harlan+2 more episodesJustice who wrote Jacobson v. Massachusetts and its four limits
- Carrie Buck+1 more episodeVirginia woman sterilized after the 1927 decision
- Henning JacobsonCambridge pastor fined five dollars for refusing smallpox vaccination
- Harry H. Laughlin+4 more episodesEugenicist whose model law underlay Virginia's statute
- Paul Lombardo+1 more episodeLegal historian who documented the collusive character of the case
- Stephen Jay Gould+2 more episodesPublished Vivian Buck's school records in 1984
- Mark Warner+1 more episodeVirginia governor who apologized in 2002
Where it happens
- Amherst County, VirginiaSite of the November 1924 trial
- Virginia State Colony, Lynchburg, VirginiaInstitution where Carrie Buck was committed and sterilized
- Cambridge, Massachusetts+1 more episodeWhere Jacobson refused smallpox vaccination
- Indiana+2 more episodesEnacted the first compulsory sterilization statute in 1907
Timeline
- February 20, 1905Jacobson v. Massachusetts upholds the vaccination fine with four limits.
- March 20, 1924Virginia signs its Eugenical Sterilization Act and Racial Integrity Act on the same day.
- May 2, 1927Buck v. Bell upholds sterilization 8-1.
- June 1, 1942Skinner v. Oklahoma strikes a sterilization law but distinguishes Buck v. Bell.
- 1974Virginia repeals its sterilization act.
- February 2015Virginia establishes compensation of up to $25,000 for each living victim.
Still debated
Virginia's total is approximate, at roughly 8,300 sterilizations between 1927 and 1972. The 1980 findings strongly suggest Carrie Buck's diagnosis was wrong, though they are not a clinical record of 1924. Whether Buck v. Bell remains good law has not been answered by the courts, and the Nuremberg citation rests on secondary accounts.
Connected episodes in other series
