Carrie Buck was nobody you would have heard of. She was born in 1906 in Charlottesville, Virginia. Soon afterward, her father either abandoned the family or died—there’s no reliable record—leaving Carrie and her mother, Emma, in dire poverty. As a toddler, Carrie was taken in, with the approval of a municipal court, by a well-to-do couple, John and Alice Dobbs, who asked to become her foster parents after seeing Emma on the street. Carrie lived with the Dobbses and went to school through the sixth grade, after which they pulled her out of school so that she could do housework full time. She cleaned their house and was hired out to clean neighbors’ homes, until, at seventeen, she was discovered to be pregnant—she later said that she’d been raped, by Alice Dobbs’s nephew—at which point her guardians moved to have her declared mentally deficient, although there was no prior evidence that this was the case. They then had her committed to the Virginia Colony for Epileptics and Feeble-Minded.
When Carrie was sent to the Virginia Colony, in 1924, the forward thinkers of America were preoccupied by the imagined genetic threat of feeblemindedness, a capaciously defined condition that was diagnosed using often flawed intelligence tests and by identifying symptoms such as moral degeneracy, an overactive sex drive, and other traits liberally ascribed to poor people (especially poor women) who were seen as having stepped out of line. (Just a few years before Carrie was committed to the Virginia Colony, Emma was also sent there. It seems that she had turned to drug use and prostitution—although it’s hard to say, since many female vagrants were labelled prostitutes.) A sloppy reading of Gregor Mendel’s pea pods and Charles Darwin’s theories gave a scientific veneer to the conclusion that many social ills were caused by the proliferation of the wrong sort of people and that they could be neatly nipped in the bud with the intervention of eugenics—a term coined, in 1883, by Darwin’s half-cousin Francis Galton, who declared it “a virile creed, full of hopefulness.” Soon, the United States, along with Germany, was at the forefront of the movement to improve the human species through breeding. Scientific American ran articles on the subject, and the American Museum of Natural History hosted conferences. Theodore Roosevelt, Alexander Graham Bell, John D. Rockefeller, Jr., and many other prominent citizens were outspoken supporters. Eugenics was taught in schools, celebrated in exhibits at the World’s Fair, and even preached from pulpits. The human race, one prominent advocate declared in 1909, was poised “to dry up the springs that feed the torrent of defective and degenerate protoplasm.”
The Virginia Colony was one of many facilities for the disabled that were founded in the Progressive Era, partly to provide care for a vulnerable population and partly to remove it from the gene pool, by sequestering those individuals during their fertile years. (On the other side of the coin, Jill Lepore has written about how modern marriage therapy grew out of one man’s effort to promote “fit” unions.) Between 1904 and 1921, the rate of institutionalization for feeblemindedness nearly tripled. Carrie was just one of this crowd, except that she happened to arrive at the Virginia Colony right at the moment when its superintendent, Dr. Albert Priddy, was looking to transform his institution from a genetic quarantine center to a sort of eugenics factory, where the variously unfit could be committed for a short time, sterilized, and then released, like cats, back into the general population, with the happy assurance that they would never reproduce.
A number of states passed laws permitting eugenic sterilization in the early twentieth century, some of which were subsequently struck down in court. Virginia passed its law in 1924, largely thanks to Priddy’s advocacy, but he was advised not to carry out any sterilizations until the law had been tested in court as far as appeals would take it. For this, he needed a patient to pin his legal case on. Carrie was a desirable candidate for several reasons. She had been declared a middle-grade moron—a technical designation, based on I.Q., that placed her relatively high on the intelligence scale, above the “idiot” and “imbecile” classifications and just below normal. Morons were considered particularly dangerous: they were smart enough to pass undetected and possibly breed with their superiors. Carrie, moreover, had had a child as an unmarried teen-ager, demonstrating the heightened sexuality and fertility—or “differential fecundity”—said to be common among the mentally deficient. Her mother and daughter had been labelled defective as well—the latter, still an infant, without any testing—providing evidence that Carrie’s reported shortcomings were hereditary. All of this added up to a terrifying spectre: Carrie was a walking womb, a pot of genetic poisons that might seep into purer bloodlines. And that is how Carrie Buck came to be at the center of the Supreme Court case Buck v. Bell, which, in an 8–1 decision, made forced sterilization for eugenic purposes legal in the United States.
“Imbeciles: The Supreme Court, American Eugenics, and the Sterilization of Carrie Buck,” by the journalist and lawyer Adam Cohen, gives a detailed account of the many forces that converged to bring about the Buck decision, tracing the intersecting paths of the people involved. He begins with Dr. Priddy, who was a true believer in the pure-blooded future. Priddy began pushing for legislation permitting eugenic sterilizations after he was sued by a patient whom he’d sterilized without her consent. He turned to a friend, a lawyer and politician named Aubrey Strode, who emerges as a fascinatingly banal character in Cohen’s account. Strode apparently wasn’t wholeheartedly in favor of the cause, but he did his job, drafting the law, suggesting the test-case approach, and representing the Colony in court. He argued the case before the Supreme Court, won, and then basically never mentioned it again. Carrie’s attorney in the case, selected by her court-appointed guardian, was a man named Irving Whitehead, a childhood friend of Strode’s and a former board member for the Colony. He collaborated with Priddy and Strode on the appeals process and handled Carrie’s case in a thoroughly negligent way.
Strode wrote his legislation based on a model law drafted by the biologist Harry Laughlin, who was the director of the Cold Spring Harbor Laboratory’s Eugenics Record Office (an epicenter for research in the field) and perhaps the most influential eugenics advocate in the country. If Strode is Eichmann in this story, then Laughlin is Goebbels. (The Nazi comparison feels justified here, if only for its literal relevance: Laughlin corresponded with German eugenicists and was enthusiastic about Hitler’s leadership, praising him for realizing that the “central mission of all politics is race hygiene.” He was also a driving force behind the Immigration Act of 1924, which set strict quotas on various undesirable races, including Jews. He urged maintaining these quotas when, not many years later, large numbers of Jews were trying to flee Europe.) The team in Virginia asked Laughlin to be an expert witness in the Buck case, and he was happy to oblige. Without meeting Carrie, he submitted a notarized statement saying that she had a “record during life of immorality, prostitution, and untruthfulness” and belonged to “the shiftless, ignorant, and worthless class of anti-social whites of the South.” He supported her proposed sterilization as a “potential parent of socially inadequate or defective offspring.”
Oliver Wendell Holmes was on the Court when the case was tried and wrote the majority opinion. Cohen pays particular attention to his role, arguing that Holmes’s reputation as a paragon of democratic wisdom is largely undeserved, and that he was, in reality, a flinty character and an arrogant élitist whose decisions favored the powerful and whose ostensibly progressive opinions were arrived at through illiberal rationale. This reading is certainly borne out by the decision he wrote for Buck v. Bell, which is five paragraphs and contains several coolly vicious flourishes, such as “It is better for 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.” He declared, in reference to Carrie’s family, that “three generations of imbeciles are enough.”
Cohen provides a detailed backstory for each character who appears, wandering sometimes confusingly far afield. But the panoramic view is instructive: one can see these men marching their agendas forward over bridges formed by social connections, whether it’s Priddy asking a friend to write him a law, Holmes being recommended for the Supreme Court by a fellow Boston Brahmin, or Laughlin getting his job at Cold Spring Harbor because he bonded with its founder over their shared love of chicken breeding. Cohen writes that there was widespread skepticism about eugenics among those whom Oliver Wendell Holmes once referred to as “the thick-fingered clowns we call the people,” but the opposition wasn’t large or organized enough to effectively counter the influential network behind the movement.
Carrie herself all but disappears in the book. This isn’t Cohen’s fault: unlike the men mentioned above, she wasn’t the sort of person to leave behind an archive. Cohen, in fact, does an admirable job collecting scraps of information about her life. She was sterilized soon after the trial, and eventually released from the Colony. She was married in 1932, and again in 1965, after her first husband died. Her daughter, who was raised by the Dobbses, died in 1932; Carrie wasn’t told about her death until months later. Her own mother, Emma, died in 1944, and Carrie found out when she arrived for a visit, two weeks after the funeral. Carrie was evidently a devoted wife who enjoyed reading the newspaper and doing crosswords and never had much money. People who knew her said that they never noticed any signs of mental deficiency. In 1980, some reporters found her and asked what she thought about the Supreme Court case that bore her name. (No one seems to have asked her before.) She said that she would have liked to have a couple of children, and that she hadn’t fully understood the nature of the sterilization procedure until several years afterward. She died in 1983, in a home for the indigent elderly.
Thirty-two states passed eugenic-sterilization laws during the twentieth century, and between sixty and seventy thousand people were sterilized under them. The rhetoric of the movement toned down after the U.S. went to war with Germany; most American eugenicists abandoned their explicit praise of the Nazi project, and the field dwindled as an area of officially sanctioned research. (The disassociation did not go both ways: Buck v. Bell was cited by the defense at Nuremberg.) But the sterilization rate remained high even after the Second World War. So many poor Southerners underwent the procedure that it became known as a “Mississippi appendectomy.” It was only in the nineteen-sixties and seventies, with evolving attitudes toward civil and human rights, that states began repealing their sterilization laws.
The culminating shock of “Imbeciles”—a book full of shocking anecdotes—is the fact that Buck v. Bell is still on the books and was cited as precedent in court as recently as 2001. Forced or coercive sterilizations never entirely went away either. In 2013, the Center for Investigative Reporting revealed that at least a hundred and forty-eight female prisoners in California were sterilized without proper permission between 2006 and 2010. Last year, a district attorney in Nashville was fired for including sterilization requirements in plea deals.
Despite these contemporary remnants of America’s involvement in eugenics, and despite the fact that the movement shaped national policy and held sway in the upper reaches of society for many years, this chapter of American history is surprisingly absent from the common conception of the country’s past. It’s not that it has been ignored by historians or journalists. The New Yorker_ _ran a lengthy four-part series on eugenics in 1984, and a number of books have been published on the topic. Many of these works approach the story of American eugenics as though it will be a surprise to the reader, which is probably a safe bet. Of the two other books on Buck v. Bell that have appeared in the past ten years, one has the subtitle “The Secret History of Forced Sterilization and America’s Quest for Racial Purity,” while the other ends by noting that the history of eugenics in the U.S. is “often forgotten.” Cohen, too, writes that “Buck v. Bell is little remembered today.” Yet it seems that the collective forgetfulness is not a matter of some well of information remaining untapped but of our inability or unwillingness to soak up what is drawn out of it.
What is hardest to forget about “Imbeciles” is the stream of grandiose invective against the supposedly unfit—the diatribes concerning “germs of dependency and delinquency” and the “world peopled by a race of degenerates and defectives.” It’s a language that combines the detachment of scientific terminology with the heat of bigoted slurs. It’s clearly from another time, but, lacking any lip service to equality and opportunity and the other touchstones of American political rhetoric, it also seems to come from another country. This is not how we talk about ourselves. And yet there are passages that sound startlingly familiar. In the debate over the Immigration Act of 1924, which excluded eugenically undesirable races from the U.S., a senator from Alabama declared, “We are coming to a pitiful pass in this great country when it is unpopular to speak the English language, the American language”—a lament that might have been taken from yesterday’s paper, except that he was bemoaning the proliferation of Yiddish.
It’s impossible, especially, to read “Imbeciles” without thinking of the current election cycle. Although the concerns of the eugenics movement don’t map neatly onto today’s political divides, patterns of thought are repeated: fears of procreation and infiltration still have force, although they’re directed not at “hopelessly vicious protoplasm” but at “anchor babies”; instead of the pure blood of the Nordic races, we hear invocations of that other superior species, the Winners. The 2016 Presidential campaign has reverberated with appeals to strength and victory and virility and contempt for weakness and failure and foreigners, hitting notes of blatant ugliness that we’re not used to hearing in the public sphere. The response in some quarters has been bafflement, as though this way of speaking had materialized out of nowhere. But perhaps it shouldn’t be so surprising. As Oliver Wendell Holmes wrote to a friend, about his pleasure in writing the Buck decision, “Sooner or later one gets a chance to say what one thinks.”
