"Three generations imbeciles are enough," Supreme Court Justice Oliver Wendall Holmes wrote in the 1927 majority decision of Buck v. Bell, which upheld the constitutionality of forced sterilization. Holmes was referring to the "manifestly unfit" Buck family women: Carrie and mother Emma, inmates at the Virginia State Colony for Epileptics and Feeble-Minded, and Carrie's infant daughter Vivian, who was presumed to be mentally deficient. As various scholars have since shown, the label "feebleminded" applied to a broad range of people, including those — like the Buck women — who unlikely had cognitive disabilities but whose marginal status provoked invasive measures of social control.
Scholars traditionally have presented this case as a watershed moment in the history of American eugenics, reproductive rights, and disability. After the Buck decision, thirty states enacted forced sterilization laws; ultimately, doctors performed involuntary sterilizations of over 60,000 Americans, including Carrie Buck. Although activism and reforms in the 1970s countered such procedures, Buck v. Bell has never been overturned and many states maintain forced sterilization laws.
Offering a critical reinterpretation of Buck v. Bell that fuses legal history with biography, Paul Lombardo reveals a complicated story of poverty, sexual oppression, disempowerment, and legal fraud. In 1920 a judge deemed Emma Buck, a widowed mother of three, to be promiscuous and mentally deficient, and committed her to the Virginia Colony. Three years later, as the result of a rape by a foster family member, teen-aged Carrie Buck became pregnant, a condition then used to justify her diagnosis as promiscuous and feebleminded. The foster family kept Carrie's daughter, Vivian. In 1924, Virginia approved a compulsory sterilization law. Hoping to solidify the burgeoning eugenics movement, Colony officials selected Carrie Buck to test Virginia's new statute.
Drawing on prodigious primary source materials, legal scholar Lombardo contends that the case was "based on deceit and betrayal, " exposing the uninhibited complicity among the Colony's Board of Directors, Carrie Buck's lawyer, and a network of eugenic advocates to gain a favorable Supreme Court decision. The directors hired friend and former board member Irving Whitehead to represent Buck. Lombardo particularly blames Whitehead, a eugenics advocate, who "failed to call any witnesses of his own, neglected properly to cross examine witnesses of his opponent, and appeared ignorant of widely published legal and scientific arguments condemning the operation Carrie Buck faced" (p. 154). As Lombardo concludes, Whitehead "did not fail in the advocacy of Carrie Buck simply because he was incompetent. Whitehead failed because he intended to fail" (p. 148).
The remainder of Three Generations examines the far-reaching impact of the court case. Like scholars Stefan Kuhl and Edwin Black, Lombardo asserts fundamental links between the American eugenics movement and the abominations of Nazi applications. In the chapters on America after the 1940s, Lombardo ultimately connects entrenched eugenic aims with current legal and scientific subjects, including the Human Genome Project and constitutional contests over reproductive freedoms. Buck's haunting example here effectively prompts critical and fruitful reappraisals.
Lombardo adroitly challenges the legal basis of the Buck case and illuminates significant connections to subsequent cases regarding reproductive and civil rights, but scholars may be disappointed that he did not include critical interpretations of the social constructions and complex meanings of disability, race, and gender in his analysis. As historians such as Stan Schuchman, James Trent, and Martin Pernick demonstrate in their works on eugenics and disability and deaf communities, critiques of the social and ideological underpinnings of concepts like "unfit" and "normal" recast our national narratives, inviting new interpretations that close the gap between lived experiences and historical concepts.
Disability studies scholars may appreciate particularly Lombardo's fusion of activism with scholarship. This is especially evident in the author's narration of his own efforts to transfer Carrie Buck's story from the locked wards of history to its mainstream narrative. Lombardo, who met Buck before her death in 1983, has participated in erecting a historical marker in Charlottesville commemorating Buck v. Bell; he continues to play a prominent role in campaigns to elicit apologies from states for their eugenic laws.
Ultimately, Three Generations provides valuable, new, and timely revelations for students and professional scholars across many disciplines.
