R. Marc Kantrowitz, BridgeTower Media Newswires
“Three generations of imbeciles are enough,” wrote perhaps the greatest of all the Supreme Court justices, Oliver Wendell Holmes Jr., in an opinion permitting the state of Virginia to sterilize Carrie Buck. There was only one problem: Carrie wasn’t an imbecile.
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A panic had set in, from the cities to the farmlands, from east to west. Both the government and charities sagged at the tonnage of the problem.
Fortunately, academia and science leaped at the opportunity to calm the waters and settle the issue as to what to do with the feeble-minded. The nation was engulfed with ideas as to how better mankind.
The leading schools, scholars and greatest minds offered guidance. Dr. Walter Fernald of Massachusetts opined that “feeble-minded women are almost invariably immoral and if at large usually become carriers of venereal disease or give birth to children who are as defective as themselves.”
The solution: the isolation and segregation of morons (mentally aged 7 to 12), imbeciles (3 to 7) and the lowest rung of them all, idiots. Soon institutions bulged with the influx of the feeble-minded, which led to a new proposition: sterilization, for the neutered could be released without fear of reproduction.
Before Virginia set its law of eugenics into action, however, it sought a court case to test its legality.
And, sadly, in wandered Carrie Buck, adjudicated feeble-minded, young, unmarried and pregnant. A living nightmare to those who sought to save the nation from the danger she presented.
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Carrie was born on July 2, 1906, to Emma and Frank. Her father disappeared after 10 years of marriage. Left on her own, Emma barely squeaked by, took up with men, and had two more children, Doris and Roy. A local well-off family, John and Alice Dobbs, offered to take in Carrie, a testament to the feelings at the time that those with money should help the less fortunate.
But the Dobbs treated Carrie far differently than their own daughter. Carrie attended school and did well, only dropping out of the sixth grade at the behest of the Dobbs. She quickly transitioned into serving as a domestic in both her house and others.
Emma, meanwhile, continued to struggle, and in 1920 found trouble. Charged with either vagrancy or prostitution, she went from court to a facility for the feeble-minded, where she was diagnosed with rheumatism, pneumonia and syphilis. Track marks on her arms indicated possible drug usage.
Given what turned out to be a highly unreliable mental test, she was adjudicated a moron. She would never be released. Carrie was now 14.
Four years later, the Dobbs petitioned to have Carrie follow her mother, claiming that she too was feeble-minded and presented a burden and menace on both them and society. Thrown in for good measure was an allegation of epilepsy.
With inadequate legal representation, Carrie could not rebut the charges. Her school records were never introduced, nor were her medical records, which bore no mention of epilepsy.
Nor was the Dobbs’ true motivation revealed: Carrie was pregnant, raped by a Dobbs’ nephew. She was sent away in an effort to silence her.
Carrie joined her mother in Virginia’s Colony for Epileptics and Feeble-Minded, which was more akin to a farm, idyllic in its setting with the hope that the pastoral nature would soothe and cure its inhabitants.
Dr. Albert Priddy, the longtime overseer of the facility, settled on Carrie as the test case for sterilization. At the hearing and court proceeding, he outlined his impressive background and testified that the morally delinquent Carrie, of “unknown paternity,” possessed the mental age of a 9-year old and that both her mother and her child, Vivian, were also mentally defective.
In the end, Priddy drew the choice: either sterilize Carrie and release her to society or have her stay in the facility for decades until she could no longer reproduce.
Carrie’s representation consisted of an attorney who was either inept or, more likely, shared the sentiments of his close friends at the institution. He introduced nothing in evidence about her school work, her teachers, her work background — indeed anything positive about her — nor did he attack her accusers.
Most egregiously, he made no challenge as to how one might accurately ascertain the mental acuity of Vivian, a baby.
Carrie lost at all levels. When the Supreme Court took the case, a growing anti-eugenicist group hoped that the believed-to-be progressive, if not liberal, Oliver Wendell Holmes would lend a sympathetic ear. Instead, their pleas fell on a deaf one.
In a pithy four-paragraph opinion, Holmes observed that “[i]t is better for all the world, if instead of waiting to execute degenerate offspring for crime, or to let them starve for their imbecility, society can prevent those who are manifestly unfit from continuing their kind. The principle that sustains compulsory vaccination is broad enough to cover cutting the Fallopian tubes.”
And thus Carrie was sterilized and released. So, too, was her 16-year-old half-sister, Doris, and thousands of others across the nation.
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Epilogue
Vivian, who did well in school and was considered “perfectly normal,” fell ill and died at 8, having never lived with her mother. Carrie married twice. After her first husband died, she eventually remarried and was, as before, devoted and hard-working, albeit in a series of low-paying and often difficult jobs.
She died in 1983, having impressed those who knew her as competent, pleasant and of normal intelligence. She, like Doris, could not understand why she was unable to get pregnant. She thought the scar on her stomach was due to an appendectomy.
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R. Marc Kantrowitz, a retired judge, can be contacted at rmarckantrowitz@comcast. net. The above column is based primarily on “Imbeciles” by Adam Cohen.
