Book Summary: Imbeciles: The Supreme Court, American Eugenics, and the Sterilization of Carrie Buck

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Imbeciles: The Supreme Court, American Eugenics, and the Sterilization of Carrie Buck, by Adam Cohen (402 pages)

Brief Overview

The Justice Oliver Wendell Holmes, honored as a great Supreme Court justice by many, was the master of the pithy saying.  In Buck v. Bell (1927), this was shown in a cruel way when he argued that “Three generations of imbeciles are enough.”  

Today, “imbecile” is a somewhat outdated way of calling someone stupid. But, in the 1920s, it had a scientific meaning as well. People deemed to have a mental disability were split into three categories: idiot (mental age below the level of three-year-olds), imbeciles (three to seven) and morons (eight to twelve).  All very scientific sounding; much less so upon scrutiny.

Imbeciles tells the story of Carrie Buck and explains how the Supreme Court decided that it was a good thing to sterilize people like her.  Carrie Buck came from a poor family and was placed in a foster home.  At a young age, she was put to work.  And, then she was raped by the nephew of her foster family.  The pregnancy helped to “prove” the Buck family was tainted.

This was the era of eugenics, the idea that controlling reproduction — by state coercion if necessary — could lead to better social “stock.”  This was the dark side of the Progressive Era, a time period where the potential for social reform included a greater push for government regulation and trust in science and experts.  Eugenics showed this could be taken too far. 

Carrie Buck was an ideal “test case” to make sure a sterilization law in Virginia would be upheld in the courts. There was some concern about the dangers of sterilization, even the person who crafted the state eugenics law was not a big fan. The book discusses the story behind that law and how Carrie Buck became a tool of the eugenics movement.  

Eugenics, especially after Nazi Germany, now is generally seen as a horrible wrong.  But, the various issues of biology and the law continue to be matters of debate.  Buck v. Bell itself was never overturned and the appropriate power of the state over our bodies “for society’s own good” continues to be debated until today.  

Favorite Quote

Faced with this choice, the Supreme Court did not merely side with the strong: it enthusiastically urged them on by insisting it would be “better for all the world” if society’s strongest members simply finished off people like Carrie once and for all.  

The book notes that the ancient Code of Hammurabi honored the principle that “the strong should not harm the weak.”  Buck v. Bell shows that sometimes the strong choose the opposite path.  The book explains why that was so.  

Should I Read It?

The biggest issue here is that Paul Lombardo wrote a book on this subject entitled Three generations, No Imbeciles: Eugenics, the Supreme Court, and Buck v. Bell.  

Lombardo is a legal historian with special emphasis on eugenics and sterilization in the United States.  His work covers much the same ground.  Some find this earlier (2008) book superior.  Lombardo’s book includes a copy of the Virginia eugenics’ law and the opinion of Buck v. Bell.  Cohen’s book is longer, adding some more narrative, but lacks those useful appendices.  

I found both good books, but there is an argument that this one is a tad … redundant.  

But, let’s focus on the current volume.  This is a well written historical narrative with special focus on five individuals involved in the events.  The book carefully discusses the history leading up to the decision. The author has special qualifications to offer a discussion of the legal issues.  The book does a good job telling a story and teaching us about the material at the same time.  

The book’s format of organizing the events by the key players does lead to some redundancies since the chapters overlap some time-wise.  The book also can be enjoyed by the general reader, but goes into a degree of detail which some might find too much.  In Reckless Hands: Skinner v. Oklahoma and the Near-Triumph of American Eugenics by Victoria F. Nourse covers a related case in about half the page length. 

Imbeciles is overall a good addition to a “cottage industry” of books that use landmark legal cases to provide insights to wider historical, social, and legal matters.  

Comprehensive Summary


Eugenics, the attempt to create a “perfect humanity” via heredity, was all the rage in the 1920s.  The eugenics movement offered two solutions: new immigration laws to limit the “wrong” type of immigrants (threat from without) and laws to limit reproduction of those “degrading the gene pool”  (threat from within).  Buck v. Bell upheld the legitimacy of the latter.  

Buck v. Bell is cited as one of the worst Supreme Court cases.  But, it is not merely “history.”  People still are being sterilized, at times against their will.  Broader questions of genetics and the law are active issues today.  And, the case is an example of the “timeless” question of power: those with it and those on the bottom without it who rely on others for protection.   

Carrie Buck

The book spends two chapters each on five figures involved in the overall story of this book, beginning and ending with Carrie Buck.  Carrie Buck was born in Virginia in 1906, part of the “southern poor white caste.”   She was eventually put in foster care.  Carrie Buck at seventeen became pregnant as a result of being raped by a nephew of her foster parents.  

Her mother was poor and ultimately labeled “feeble-minded” though (as with Carrie and her daughter) there was no real evidence that she was.  The science of determining intelligence, then in its infancy and a very “inexact science,” is discussed.  

Her foster parents had her committed to a state institution on grounds of being feebleminded and epileptic (though there is no evidence she was), hiding the true nature of her pregnancy.   Carrie had a daughter, Vivian, who her former foster parents cared for.  

At this time, the leaders of the state hospital system were looking for a “test case” to determine if its sterilization law was legally acceptable.  She was a prime candidate. 

Albert Priddy

Albert Priddy was born in 1865.  He dedicated his life to the science of mental health, ultimately being appointed to be superintendent of the Virginia State Epileptic Colony, which added the “feeble-minded” to their mission shortly thereafter. The chapter discusses the history of eugenics and how it grew out of more reputable Darwinian evolutionary ideas.  

Dr. Priddy was a big supporter of eugenics and started to sterilize inmates at the colony based on vague reasons of “immorality” or “feeble-mindedness.”  This at first was legally dubious, but then Virginia passed a law specifically allowing it.  Carrie Buck would be used to test its legality, her pregnancy being shown as proof that she was sexually promiscuous as well as feeble-minded.

During the litigation, Dr. Priddy died.  Dr. John Bell became the new head of the colony. 

Harry Laughlin

Harry Laughlin was born in Iowa in 1880.  His father was a deep believer in education and religious faith.  His mother supported women’s suffrage and temperance. Laughlin later specialized in breeding, moving on to the related field of eugenics. Laughlin couched his racist beliefs, including against immigrants, in scientific sounding language.  

He was chosen as the top expert in the trial to determine that Carrie Buck was a suitable subject for sterilization.  The “dubious assertions” made, including a determination that Carrie Buck’s six-month-old daughter Vivian was “considerably feebleminded” are discussed.   

Aubrey Strode

Audrey Strode (born 1873) like Carrie Buck and Albert Priddy was born in Virginia though Carrie Buck alone was deemed of “inferior stock.”  

Strode’s legal and political career are discussed.  Strode had typical racist beliefs for the time though supported women’s suffrage.  Strode, perhaps because his own parents suffered from mental illness, was particularly concerned about mental health policy.  

Strode not only crafted the law involved but defended it all the way to the Supreme Court.  

Irving Whitehead was appointed as Carrie Buck’s legal guardian.  Whitehead, however, not only supported the eugenics law.  He basically worked with the state to uphold the law.  His defense was problematic in various ways.  Carrie Buck really had no true advocate on her side.  

Oliver Wendell Holmes

Justice Oliver Wendell Holmes was eighty-six years old at the time of Buck v. Bell.  His long life and career are examined.  Holmes was honored by progressives of the day for supporting free speech and the discretion of state legislatures to regulate public policy.  But, he also looked the other way regarding a range of racist laws, and was a strong supporter of eugenics.  

Justice Holmes wrote the opinion of Buck v. Bell, with only a conservative Catholic justice (without a written opinion) dissenting.  It was a brief, and in various ways shoddy opinion, especially how it spun the facts.  Many other courts carefully addressed eugenics laws, so Holmes upholding this one in a dismissive fashion is particularly notable.  

The opinion infamously argued that “three generations of imbeciles is enough.”  This is one final injustice. Emma and Carrie Buck were actually found to be “morons,” ironically the most “intelligent” of the three mental deficiency categories.  Holmes basically downgraded them into the “imbecile” category.  His looseness of language does underline the problems with eugenics.  

Carrie Buck

Carrie Buck was sterilized as was her half-sister.  Her daughter died of an illness at a young age. Vivian Buck’s school records show she was of normal intelligence.  Carrie Buck later married and lived a quiet life.  She showed devotion to family and “a quiet intelligence.”  


The chapter discusses the lives of the key players after the ruling.  Buck v. Bell was never overruled, though Skinner v. Oklahoma (1942) struck down a eugenics law on equal protection grounds.  Eugenics became disfavored, especially with Nazi Germany.  But, we should not think that the “progessive” ideals behind it could not arise in some other form again.  

Points to Ponder

Oliver Wendell Holmes, the author of Buck v. Bell, is honored by many today as a great legal mind.  But, the book shows this is not his only dubious legal opinion.  Consider the complexity of such historical figures, and why we should not have a simplistic view of them.

Buck v. Bell was a 8-1 opinion, but many lower courts beforehand had struck down eugenics laws on various grounds.  None of the Bucks were in fact so-called “imbeciles.”  A basic part of the travesty of the case was that another path was possible.  Horrible choices were made.  

About the Author

Adam Cohen is a journalist and author.  He graduated from Harvard Law School and was president of the Harvard Law Review.   You can listen to him discuss this book here.

He also wrote:

Is Imbecibles a Reliable Read?

Paul Lombardo is a legal historian with special emphasis on eugenics and sterilization in the United States.  I think his book would be deemed most reliable on this subject.  

But, Adam Cohen has the legal and historical chops to handle the material as well.  The book is well researched with extensive endnotes.