In 1927 the Supreme Court ruled eight to one that Virginia could sterilize Carrie Buck against her will. She was a young woman who had been raped and committed to an institution, and her case was a staged test case. Justice Holmes wrote of three generations of imbeciles, and more than 60,000 Americans were sterilized in over 30 states under a precedent never overturned.
Exact sterilization totals vary by state and some records are incomplete. Historians debate whether Holmes was a convinced eugenicist or a jurist deferring to legislatures, and legal scholars differ on the precedent's current force since it was never formally overturned.