LC Journal of Special Education

Article Title

Buck v. Bell: Eighty Years of Challenges for Parents with Developmental Disabilities


On May 2nd, 1927, Justice Oliver Wendell Holmes delivered the Supreme Court‟s decision in the case of Carrie Buck v. J.H. Bell (Smith & Nelson, 1989). In the majority opinion, Holmes stated that, “It is better for all the world, if instead of waiting to execute 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...” (Smith & Nelson, 1989, p.178). Thus, it was determined that “three generations of imbeciles [were] enough”, and the poster woman for American eugenics would be a victim of involuntary sterilization (Smith & Nelson, 1989, p.178). Perhaps unknown to Holmes, the outcome of Buck v. Bell was far-reaching beyond just Carrie Buck. This monumental court decision opened the door for many states, including Virginia, to enact a sterilization law. In addition, it helped nurture a stigma against people with disabilities as being unfit for life and parenting. The stigma can still be seen today in both social and political contexts as noted in contemporary court cases (e.g., Holtz v. Holtz and Hankins v. Hankins).