"Three generations of idiots is enough," United States Supreme Court Chief Justice Oliver Wendell Holmes infamously declared in authorizing the involuntary sterilization of Carrie Buck, age twenty-one, in Virginia. 1
What had Carrie done to deserve this fate? She was born poor and powerless, the daughter of a prostitute. In 1924, at the age of seventeen, she became pregnant out of wedlock, apparently after being raped by a relative of her foster father. To cover up this heinous act, Carrie's foster family had her declared morally and mentally deficient, after which she was involuntarily institutionalized in an asylum.
Adding to Carrie's woes, in 1924 the State of Virginia enacted a law permitting "mental defectives" to be involuntarily sterilized for the betterment of society. Asylum doctors decided that Carrie was a "human defective" and therefore a good candidate for the procedure. Her mother was institutionalized, after all, and her baby, age seven months, did not look "quite normal." 2 Thus, they figured, society would be best served if Carrie's genes were removed from the human race.
Carrie's guardian tried to stop the involuntary surgery in court. But the trial judge instead ordered that the sterilization proceed, relying on "experts" who testified that Carrie had unfit genes. The case