Three Generations, No Imbeciles: Eugenics, the Supreme Court, and Buck v. Bell

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Overview

"Three generations of imbeciles are enough." Few lines from Supreme Court opinions are as memorable as this declaration by Justice Oliver Wendell Holmes Jr. in the landmark 1927 case Buck v. Bell. The ruling allowed states to forcibly sterilize residents in order to prevent "feebleminded and socially inadequate" people from having children. It is the only time the Supreme Court endorsed surgery as a tool of government policy. Paul Lombardo’s startling narrative exposes the Buck case’s fraudulent roots.

In 1924 Carrie Buck—involuntarily institutionalized by the State of Virginia after she was raped and impregnated—challenged the state’s plan to sterilize her. Having already judged her mother and daughter mentally deficient, Virginia wanted to make Buck the first person sterilized under a new law designed to prevent hereditarily "defective" people from reproducing. Lombardo’s more than twenty-five years of research and his own interview with Buck before she died demonstrate conclusively that she was destined to lose the case before it had even begun. Neither Carrie Buck nor her mother and daughter were the "imbeciles" condemned in the Holmes opinion. Her lawyer—a founder of the institution where she was held—never challenged Virginia’s arguments and called no witnesses on Buck’s behalf. And judges who heard her case, from state courts up to the U.S. Supreme Court, sympathized with the eugenics movement. Virginia had Carrie Buck sterilized shortly after the 1927 decision.

Though Buck set the stage for more than sixty thousand involuntary sterilizations in the United States and was cited at the Nuremberg trials in defense of Nazi sterilization experiments, it has never been overturned. Three Generations, No Imbeciles tracks the notorious case through its history, revealing that it remains a potent symbol of government control of reproduction and a troubling precedent for the human genome era.

Johns Hopkins University Press

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Editorial Reviews

Metapsychology - Susan L. Smith
This book is suitable for any audience interested in the history of the eugenics movement in the United States.
Isis - Brent Ruswick
Three Generations, No Imbeciles chronicles Buck's tragic life and reviews the larger history of American eugenics in a moving narrative that will appeal to a broad audience of lay readers interested in controversies over reproductive rights, public health, science, and the law.
Comptes Rendus Biologies - Jana Grekul
Compelling.. brilliant... and refreshing.
Choice
Overall, a fascinating book on one of the darker decisions in US law. An excellent addition to collections on US constitutional law, history, and reproductive rights.
Psychiatric Services
Meticulously detailed and researched history... this book is enjoyable, thought provoking, and troubling in equal measure. I highly recommend it.

— Susan Stefan, J.D.

Disability Studies Quarterly
Three Generations provides valuable, new, and timely revelations for students and professional scholars across many disciplines.

— Susan Burch

Commonweal
Meticulously researched... As Lombardo conclusively demonstrates, those who sought to have Buck sterilized did not let the facts get in the way of the story the law required them to tell.

— Paul Lauritzen

Harvard Law Review
Compelling and well-researched... Three Generations, No Imbeciles gives Carrie Buck's long-untold story the attention it deserves.
PsycCRITIQUES
This book is a legal and historical masterpiece, combining meticulous ethical analysis with a liveliness that belies its scholarly roots and exhaustive footnotes and research.

— Michael B. Blank

Virginia Lawyer
In a very readable 279 pages, Paul A. Lombardo sets forth the facts about the eugenics movement in the United Sates.

— Robert T. Adams

Journal of the History of Medicine and Allied Sciences
Heartbreaking and riveting... There is likely to be no better account of Buck v. Bell than Lombardo's book.

— Ian Dowbiggin, Ph.D.

American Journal of Bioethics
The struggle for justice goes on. Bioethicists typically ask 'ought' questions, but not all follow up with activism. More bioethicists should accept the social activist role. Paul Lombardo demonstrates exactly how it can be done.

— Ruth Levy Guyer

USA Today
For almost 30 years, Lombardo has tried to uncover the full story of the wrongs.

— Andrea Pitzer

Quarterly Review of Biology
What makes Lombardo's analysis so important is that issues about the fate of our mutant genes, about the use of technologies to monitor pregnancies at risk for birth defects, and alternatives to relying on chance alone are subverted by our fear of eugenics.

— Elof Axel Carlson

Choice

Overall, a fascinating book on one of the darker decisions in US law. An excellent addition to collections on US constitutional law, history, and reproductive rights.

Internet Review of Books
Lombardo tells a compelling and heavily documented story of injustice to society’s less fortunate citizens. His sympathy for the abused is evident, but that does not turn Three Generations, No Imbeciles into a polemic... Armed with knowledge from this excellent book, we can hope we never return to the mistakes of our past.
New England Journal of Medicine
The book is lucidly written, well researched, thorough, and provocative... Three Generations, No Imbeciles is a must read for anyone who wants to understand the historical context of Buck v. Bell and its implications for ethics, law and public policy.
Booklist
An engrossing look at a shameful case.
Pathophilia
Lombardo reminds us that the same incentives to improve public health and lower tax burdens exist today.
History News Network
A sad and fascinating book... With his legal and historical background, Lombardo is particularly suited to give us a book that explains a surprisingly ignored injustice, its antecedents and consequences, and helps us to think about the ongoing struggle to find a health balance between privacy and government power.

— Stephen Murdoch

Reason
Startling.

— Damon W. Root

Journal of Legal Education
As a historical endeavor, it is rich and rewarding, permitting the reader a broad understanding of the social, cultural and legal context for the case that inspired Oliver Wendell Holmes' famous quotation, 'Three generations of imbeciles are enough.'... Equally important as the excavation of this history is the manner in which Lombardo's writing surfaces the emotional consequences of fertility-related policies.

— Michelle Oberman

Law & Society Review
Lombardo does an excellent job of meticulously laying out the sham nature of Buck v. Bell, and by the end of the text, the reader is left with no doubt that the case, which has never been overturned, was mired in deceit... Fascinating nuggets of racial politics, class inequality, and fear of the female body.
Magill Book Reviews
A powerful commentary on the dangers of politicized medicine and social engineering.

— Daniel P. Murphy

Virginia Magazine of History and Biography
A remarkable work of investigation and narrative synthesis, Lombardo connects Buck v. Bell to a broader debate over the place of eugenics in American life and law... Having amassed over two decades of research, including interviewing Carrie Buck, Lombardo is uniquely qualified to tell this story.

— Jason Morgan Ward

American Historical Review
This painstakingly researched book will surely be the definitive study of Buck v. Bell for many years to come.

— Diane B. Paul

Isis
Three Generations, No Imbeciles chronicles Buck's tragic life and reviews the larger history of American eugenics in a moving narrative that will appeal to a broad audience of lay readers interested in controversies over reproductive rights, public health, science, and the law.

— Brent Ruswick

Nursing History Review
Lombardo convincingly shows that the eugenics of the 1920s, despite professional reversals and government apologies, still echoes in discussions of designer babies, grumbling about the costs of social programs and attempts to calculate the financial value of life.

— Edward Slavishak, PhD

Criminal Law Library Blog
Highly recommended for academic, public, and law libraries.

— Philip Y. Blue

Metapsychology
This book is suitable for any audience interested in the history of the eugenics movement in the United States.

— Susan L. Smith, Ph.D.

Comptes Rendus Biologies
Compelling.. brilliant... and refreshing.

— Jana Grekul

Criminal Law Library Blog - Philip Y. Blue
Highly recommended for academic, public, and law libraries.
Reason - Damon W. Root
Startling.
History News Network - Stephen Murdoch
A sad and fascinating book... With his legal and historical background, Lombardo is particularly suited to give us a book that explains a surprisingly ignored injustice, its antecedents and consequences, and helps us to think about the ongoing struggle to find a health balance between privacy and government power.
PsycCRITIQUES - Michael B. Blank
This book is a legal and historical masterpiece, combining meticulous ethical analysis with a liveliness that belies its scholarly roots and exhaustive footnotes and research.
Virginia Lawyer - Robert T. Adams
In a very readable 279 pages, Paul A. Lombardo sets forth the facts about the eugenics movement in the United Sates.
Commonweal - Paul Lauritzen
Meticulously researched... As Lombardo conclusively demonstrates, those who sought to have Buck sterilized did not let the facts get in the way of the story the law required them to tell.
Psychiatric Services - Susan Stefan
Meticulously detailed and researched history... this book is enjoyable, thought provoking, and troubling in equal measure. I highly recommend it.
Disability Studies Quarterly - Susan Burch
Three Generations provides valuable, new, and timely revelations for students and professional scholars across many disciplines.
USA Today - Andrea Pitzer
For almost 30 years, Lombardo has tried to uncover the full story of the wrongs.
H-Law, H-Net Reviews - Lynne Curry
Most thorough examination to date... Readers will be both intrigued and disturbed by what they encounter.
Quarterly Review of Biology - Elof Axel Carlson
What makes Lombardo's analysis so important is that issues about the fate of our mutant genes, about the use of technologies to monitor pregnancies at risk for birth defects, and alternatives to relying on chance alone are subverted by our fear of eugenics.
American Journal of Bioethics - Ruth Levy Guyer
The struggle for justice goes on. Bioethicists typically ask 'ought' questions, but not all follow up with activism. More bioethicists should accept the social activist role. Paul Lombardo demonstrates exactly how it can be done.
Journal of the History of Medicine and Allied Sciences - Ian Dowbiggin
Heartbreaking and riveting... There is likely to be no better account of Buck v. Bell than Lombardo's book.
Virginia Magazine of History and Biography - Jason Morgan Ward
A remarkable work of investigation and narrative synthesis, Lombardo connects Buck v. Bell to a broader debate over the place of eugenics in American life and law... Having amassed over two decades of research, including interviewing Carrie Buck, Lombardo is uniquely qualified to tell this story.
Journal of Law, Medicine & Ethics - John G. Browning
Three Generations, No Imbeciles manages to be both a meticulously researched work of history and a compelling story.
Magill Book Reviews - Daniel P. Murphy
A powerful commentary on the dangers of politicized medicine and social engineering.
American Historical Review - Diane B. Paul
This painstakingly researched book will surely be the definitive study of Buck v. Bell for many years to come.
Journal of Legal Education - Michelle Oberman
As a historical endeavor, it is rich and rewarding, permitting the reader a broad understanding of the social, cultural and legal context for the case that inspired Oliver Wendell Holmes' famous quotation, 'Three generations of imbeciles are enough.'... Equally important as the excavation of this history is the manner in which Lombardo's writing surfaces the emotional consequences of fertility-related policies.
Nursing History Review - Edward Slavishak
Lombardo convincingly shows that the eugenics of the 1920s, despite professional reversals and government apologies, still echoes in discussions of designer babies, grumbling about the costs of social programs and attempts to calculate the financial value of life.
Publishers Weekly

Law professor and historian Lombardo does a superb job of revealing, for the first time, all the facts in the infamous Buck v. Bell case of the 1920s, the Supreme Court decision ratifying Virginia's compulsory sterilization of "feebleminded" people. In the majority decision, Chief Justice Oliver Wendell Holmes Jr. called the plaintiffs "manifestly unfit" both mentally and morally, and insisted that "three generations of imbeciles are enough." This decision-which has never been overturned-led to tens of thousands of involuntary sterilizations. Lombardo interviewed the last survivor of the three Buck women who were plaintiffs; turned up indisputable evidence that there was no feeblemindedness in that family; unearthed previously unknown correspondence of Carrie Buck's attorney, who, believing the law to be necessary, mounted a deliberately insufficient defense; and documented the private family tragedy (an incestuous rape and resulting pregnancy) that lay behind the Bucks' encounter with doctors bent on exploring eugenics. His book is a testament to injustice and to ignorance-not that of the Buck women, but rather of powerful doctors, attorneys and Supreme Court justices. 17 b&w photos. (Oct.)

Copyright © Reed Business Information, a division of Reed Elsevier Inc. All rights reserved.
Library Journal

Lombardo (law, Georgia State Univ.) traces a seminal 1927 Supreme Court case arising from the attempt by authorities in Virginia to force the sterilization of a woman believed to be mentally and socially "insufficient." Lombardo carefully re-creates the trial, which resulted in a ruling formally endorsing the sterilization of Carrie Buck. The case quickly advanced to the U.S. Supreme Court, where the justices ruled that the sterilization law did not violate the Eighth Amendment. Lombardo minces no words in expressing his disdain for the lackluster performance and conflicts of interest of Buck's attorney. Carrie's fate before the Court, argues the author, was partially attributable to social Darwinism as well as the attitude of the Court's chief social arbiter, Oliver Wendell Holmes Jr., that society should not bear the burden of people born without pedigree, status, intelligence, or capacity. Lombardo observes that by the early 1970s medical science had strongly discredited the notion that bad heredity could be interrupted by sterilization, and the entire movement ground to a screeching halt. This original study is highly recommended for academic, public, and law libraries.
—Philip Y. Blue

Doody's Review Service
Reviewer: Suzanne M Shultz, MA (York Hospital)
Description: This book about the Buck v. Bell Supreme Court decision and its lasting implications for eugenic sterilization policies broadly describes the U.S. eugenics movement, its history and prime movers, the creation of a "Model Sterilization Law" in Virginia, and the adoption of numerous state laws permitting sterilization surgery. The events surrounding the Buck v. Bell test case, the players, the testimony, arguments, decisions, appeals, and reactions are carefully considered. The title is drawn from the majority opinion written by Oliver Wendell Holmes Jr. in the 1927 case.
Purpose: The author points to recent genetic advances, notably the Human Genome Project, as his impetus for writing this book. He notes, "The recent triumphs in genetic science announced alongside revelations and recriminations about eugenics — and happening alongside ongoing challenges to reproductive rights - suggest that we have much to learn about Buck v. Bell. This book is the starting point in our lesson." He adds, "Buck is regularly mentioned in books on law, science, and medical history, but has never been adequately explained in a well-documented book of its own. This book tells that story, a notorious - and still open - chapter in U.S. history."
Audience: Medical practitioners, students, and historians; scientists; lawyers; legislators; ethicists; public health workers; social workers; behavioral health practitioners; general historians; and the public will appreciate the value of this work. Paul Lombardo, PhD, JD is professor of law at the Georgia State University College of Law and is widely published on eugenics and involuntary sterilization surgery, including the Buck decision.
Features: The core of the book is in the middle chapters where creation of the Virginia sterilization law is detailed and the stage is set for the Buck v. Bell test case. Five chapters are devoted to the conduct of the trial, the appeals in Virginia and ultimately the U.S. Supreme Court decision. Two additional chapters summarize the reactions to the decision and the subsequent lives of the people involved. Notably worthwhile is the history of the eugenics movement, the biographical sketches of its leaders, and their research methodologies. Connections between and exchange of research procedures and philosophy with the Nazi regime prior to and during World War II and Germany's implementation of eugenic sterilization on a massive scale comprises a chapter. The use of U.S. eugenic publications and application of its established legal foundations which were employed in defense of activities of Nazi physicians at the Nuremberg trials is disclosed in another chapter. Setting aside for the moment the broader issue of eugenics, the trial of Carrie Buck is portrayed as a miscarriage of justice, the result of the failure of her defense attorney's fiduciary duty. The author builds his case in the clear and unemotional style of the law. His assessment, however, is not without passion. Carrie Buck's attorney did not fail "simply because he was incompetent; Whitehead failed because he intended to fail." Buck v. Bell mocks the right to a fair trial and certainly violates the spirit of fair play. The outcome of the eugenics movement may have been quite different had Virginia's "Model Law" embodied in Carrie Buck failed to receive the judicial stamp of approval thus erasing Holmes's infamous words "Three generations, no imbeciles."
Assessment: There is a relative paucity of information about Carrie Buck and the Buck v. Bell trial in both book and journal literature and certainly none that provides as much detail as this one does. For this analysis alone, this book is highly recommended. The eugenics material is a bonus.
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Product Details

  • ISBN-13: 9780801898242
  • Publisher: Johns Hopkins University Press
  • Publication date: 8/31/2010
  • Edition description: New Edition
  • Pages: 384
  • Sales rank: 633,202
  • Product dimensions: 5.90 (w) x 8.90 (h) x 1.00 (d)

Meet the Author

Paul A. Lombardo is a professor of law at Georgia State University College of Law. He has played a key role, as both a historian and a lawyer, in the movement to solicit state apologies and legislative denunciations of past eugenics laws.

Johns Hopkins University Press

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Table of Contents

Prologue: The Expert Witness 1

1 Problem Families 7

2 Sex and Surgery 20

3 The Pedigree Factory 30

4 Studying Sterilization 42

5 The Mallory Case 58

6 Laughlin's Book 78

7 A Virginia Sterilization Law 91

8 Choosing Carrie Buck 103

9 Carrie Buck versus Dr. Priddy 112

10 Defenseless 136

11 On Appeal: Buck v. Bell 149

12 In the Supreme Court 157

13 Reactions and Repercussions 174

14 After the Supreme Court 185

15 Sterilizing Germans 199

16 Skinner v. Oklahoma 219

17 Buck, at Nuremberg and After 236

18 Rediscovering Buck 250

Epilogue: Reconsidering Buck 267

Acknowledgments 281

App. A The Supreme Court Opinion in Buck v. Bell, by Justice Oliver Wendell Holmes Jr. 285

App. B Virginia Eugenical Sterilization Act, 1924 288

App. C Laws and Sterilizations by State 293

Notes 295

A Note on Sources 355

Index 357

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