Buck v. Bell

Rule of Law:

A state statute permitting the compulsory sterilization of intellectually disabled individuals institutionalized by the state does not violate the Due Process or Equal Protection Clauses of the Fourteenth Amendment when the state's interest in public welfare is deemed to outweigh the individual's interest in bodily integrity and procreation.

Facts:

• Carrie Buck was a woman who was institutionalized at the Virginia State Colony for Epileptics and Feeble Minded after being deemed 'feeble minded.'
• Carrie Buck's mother was also an inmate at the same institution and was also considered 'feeble minded.'
• Carrie Buck had given birth to an illegitimate child who was likewise deemed 'feeble minded.'
• At the time of her trial court proceeding, Carrie Buck was eighteen years old.
• A 1924 Virginia law permitted the sexual sterilization of inmates in certain state institutions if the institution's superintendent determined it was in the best interest of the patient and society.
• The superintendent of the State Colony determined that it was in the best interest of society and Carrie Buck for her to be sterilized.

Procedural Posture:

• The superintendent of the Virginia State Colony for Epileptics and Feeble Minded petitioned a special board of directors for an order to sterilize inmate Carrie Buck.
• The special board granted the order for sterilization.
• Carrie Buck appealed the board's decision to the Circuit Court of Amherst County, Virginia.
• The Circuit Court affirmed the sterilization order, finding that Buck was 'the probable potential parent of socially inadequate offspring.'
• Carrie Buck, the appellant, appealed the Circuit Court's judgment to the Supreme Court of Appeals of Virginia, the state's highest court.
• The Supreme Court of Appeals of Virginia affirmed the judgment of the Circuit Court.
• The U.S. Supreme Court granted a writ of error to review the judgment of the Supreme Court of Appeals of Virginia.