Throughout the early to mid 20th century there have been some very important cases in Virginia involving the Eugenics movement and the 1924 Racial Integrity Act. These cases involved everyday individuals that were classified as not fitting Virginia Standards that were put into place by Government officials as a way of keeping a power balance. Several of these individuals were discriminated against because of their racial, social, and economic background as well as their mental state. Many of these individuals would be inhumanly sterilized against their will as well as other things.

Buck v. Bell in the Court of Appeals of Virginia in 19251

Back Ground

When talking about Eugenics in Virginia history and society it is crucial to recognize the famous Buck v. Bell case that took place in the 1920s. Carrie Buck was born to Emma and Frank Buck in Charlottesville, Virginia, however she would not know her parents because she was sent to live with her foster parents at a very young age. In the book Three Generations, No Imbeciles, the author Paul A. Lombardo talks about how in January of 1924 Carrie Buck’s foster mother was going to send her away because Carrie who was 17 at the time became pregnant with child.2 Carrie Buck’s foster mother was concerned by Carries behavior because she wasn’t married as well as other factors for this time period. In Elizabeth Catte’s book Pure America: Eugenics and the Making of Modern Virginia, we learn that the story had more to it then what would appear. When Carrie was 17 years old “Carrie was raped by Clarence Garland, Alice Dobbs’s nephew and she became pregnant. Looking to avoid scandal, the Dobbses soon discovered that in Virginia in 1924, it was as easy to commit a poor young women to an institution as it was to make her a maid at the age of ten”.3 Carrie already didn’t have a good life with the Dobbses because of the way that they treated ever since she came to live with them. Her foster parents claimed that Carrie “was subject to ‘some hallucinations and some outbreaks of temper’ and that she was dishonest…she had been born with an unusual mental condition that had been demonstrated by certain ‘peculiar actions.'”4 What Carrie’s foster parent’s wrote about her concerning her health and well being had some wholes in what they were saying. When Dr. Albert Priddy was reviewing Carrie Buck he “thought the Dobbses’ report concerning Carrie’s ‘temper and hallucinations’ was inaccurate; he found no evidence of psychosis. He noted that she could read and write and ‘keeps herself in a tidy condition'”5 It seems like Carrie’s foster parents just came up with these accusations based on Dr. Priddy’s findings while Carrie was being looked over for institutionalization.

Carrie and Emma Buck right before the Buck v. Bell trial in 19246

Admittance to the Institution

Carrie Buck was admitted into the The Virginia State Colony for Epileptics and Feebleminded. This hospital was a government run hospital located in Amherst County, Virginia. This was the same mental institution where Carrie’s mother Emma had been admitted too, a couple of years earlier. Dr. Priddy in a method to connect Carrie’s mental state and actions he tried looking through her family lines. When Dr. Priddy couldn’t find Carries father he “judged that the ‘line of baneful heredity’ came through Emma; since all of the Bucks and Harlows who lived at the Colony came from the Charlottesville and Albermarle County, he concluded that ‘they are of the same stock.'”7 By this statement Dr. Priddy much like other Eugenicists of the time was comparing a families gene pool and determining it to be a factor for what they considered to be “defectives” within Virginia society.

Chart describing levels of “Feeblemindedness” in 19158

Sterilization:

After people like Dr. Priddy came to the conclusion that what they considered to be a threat to Virginian society was hereditary, they decided to move towards forced sterilization. Robert J. Cynkar states that “one had merely to segregate them during their fertile years, or sterilize them, to rid society of their kind, humanely and permanently.”9 By sterilizing patients such as Carrie Buck Eugenicists believed that it would rid the world of the people that they thought threatened Virginia’s superior. In 1925 Carrie Bucks case went to the Virginia Court of Appeals where it was heard and then in 1927 it went to the Supreme Court. During this second trial the court stated that Carrie Buck could be sterilized based off of their findings of her mother and offspring being all considered “feebleminded” and the Judge famously stated “Three generations of imbeciles are enough.”10 This just goes to show how almost every high ranking official thought in correlation of keeping people that they thought to be inferior to them in place.

Additional information on Carrie Buck and the Eugenics Movement

https://www.npr.org/2018/04/23/604926914/emma-carrie-vivian-how-a-family-became-a-test-case-for-forced-sterilizations.

The link above is from a podcast put out by Hidden Brain and provides great details about Carrie Buck, what went on in her life as well as excerpts from a real interview that was conducted with Carrie years later after the events of Buck v. Bell.

  1. https://edu.lva.virginia.gov/dbva/items/show/227 []
  2. Lombardo, Paul A. Three Generations, No Imbeciles : Eugenics, the Supreme Court, and Buck v. Bell. Baltimore: Johns Hopkins University Press, 103. []
  3. Catte, Elizabeth. Pure America: Eugenics and the Making of Modern Virginia. First edition. Cleveland, Ohio: Belt Publishing, 2021, 26. []
  4. Lombardo, Paul A. Three Generations, No Imbeciles : Eugenics, the Supreme Court, and Buck v. Bell, 103 []
  5. Lombardo, Paul A. Three Generations, No Imbeciles : Eugenics, the Supreme Court, and Buck v. Bell. Baltimore, 105. []
  6. M.E. Grenander Department of Special Collections and Archives, University at Albany, SUNY []
  7. Lombardo, Paul A. Three Generations, No Imbeciles : Eugenics, the Supreme Court, and Buck v. Bell. Baltimore, 111. []
  8. Bottom, Davis. “Mental Defectives in Virginia.” Internet Archive, January 2011. https://archive.org/details/mentaldefectives00virg/page/6/mode/1up. []
  9. Cynkar, Robert J. “Buck V. Bell: ‘Felt Necessities’ V. Fundamental Values?” Columbia Law Review 81, no. 7 (1981): 1418–61. https://doi.org/10.2307/1122204. []
  10. Cynkar, Robert J. “Buck V. Bell: ‘Felt Necessities’ V. Fundamental Values?” Columbia Law Review 81, no. 7 (1981), 1419. []