Three Generations of “Imbeciles”

Though neither Carrie Buck nor her mother or daughter were actually disabled, to Priddy, and to the rest of the Virginia Colony, they presented an opportunity—the opportunity to use three generations of hurt, systemically abused women to establish forced sterilization as constitutional. Senator Aubrey Strode, one of Priddy’s close acquaintances that wanted the Virginia Sterilization Act to continue unimpeded, saw two major constitutional challenges to the law. 

The first was the issue of due process, in that sterilization laws in several other states were found to be considered unlawful when they failed to include specific procedural safeguards. Despite the clear lack of due process, Strode claimed that he had “so carefully prepared the Virginia Act to meet this objection that he considered the question of its [un]constitutionality on this ground negligible.”

The second challenge to the Virginia Sterilization Act was that of equal protection. Because sterilization to only those in the Colony would be considered discriminatory against those housed there, Strode worried that the Act would be deemed unconstitutional. 

The solution to their issue came in the form of eighteen-year-old Carrie Buck. Both she and her mother were poor, single women considered “feebleminded” and “promiscuous.” Her mother was institutionalized when she was just three years old, and Carrie Buck was sent to live with foster parents John and Alice Dobbs. At seventeen, her foster family’s nephew raped her, and after her foster parents petitioned to have her similarly institutionalized, Buck was sent to live in the Virginia Colony. 

In 1924, Buck gave birth to Vivian Buck, and several Red Cross health workers described infant Vivian Buck as “not quite a normal baby.” Years later, before Vivian Buck’s death of an intestinal disorder in 1932, she was in her school’s honor roll. 

Despite Strode’s assurance that due process would not be an issue in a court of law, it is clear that there was a significant lack of factual content in this case. Carrie Buck, her mother, and her daughter were incorrectly diagnosed with a pseudo-illness, allowing them to be the perfect “test case” for Strode, Priddy, and the rest of the Colony’s management to take advantage of. 

Carrie Buck, as well as her younger sister, Doris Buck Figgins, were sterilized, becoming the first of 7200 to 8000 Virginians sterilized under this law. 

To Strode and Priddy, Carrie Buck was simply the proof they needed to present to the court for the Virginia Sterilization Act to be deemed constitutional. 

To prolific Justice Oliver Wendell Holmes, Carrie Buck was what he needed to write the words that would define this case: “Three generations of imbeciles are enough.”