“Three generations of imbeciles are enough” were the infamous words U.S. Supreme Court Justice Oliver Wendell Holmes Jr. wrote in 1927. In Buck v. Bell, an almost unanimous Court upheld a Virginia law allowing the sterilization of people the state found to be “socially inadequate” and “feebleminded.” This landmark decision allowed the eugenics movement to take full effect, with multiple states passing similar laws. 

In Three Generations, No Imbeciles: Eugenics, the Supreme Court, and Buck v. Bell (Johns Hopkins UP, 2022), Dr. Paul Lombardo unpacks the case of an individual – Carrie Buck – to argue that the case not only represents the collective power of the eugenics movement in the early 20th century but an individual miscarriage of justice. Using extensive archival sources, Dr. Lombardo demonstrates that Carrie Buck was neither a “moral degenerate” or “feeble-minded.” She was a rape victim of sound mind. Her sterilization was based on fraudulent evidence. The powerful eugenics lobby manufactured a case – and a sympathetic court gave them a precedent that justified Carrie Buck’s sterilization – and over 60,000 sterilizations in the following decades.

Three Generations, No Imbeciles frames the history of sterilization as essential to understanding contemporary legal fights over birth control and abortion. Does the constitution’s promise of “liberty” include the right to become pregnant or end a pregnancy? Dr. Lombardo’s epilogue and afterward outlines the connections between Buck and modern cases involving abortion, disability rights, and reparations for those sterilized. Originally published in 2008, the book has been updated in 2022 with a terrific epilogue and afterward with an eye towards contemporary events in reproductive politics.

Dr. Paul A. Lombardo is Regents’ Professor and Bobby Lee Cook Professor of Law at the Center for Law, Health & Society at Georgia State University. He has published extensively on topics in health law, medico-legal history, and bioethics and is best known for his work on the legal history of the American eugenics movement. His website houses the images and all documents discussed in the podcast including the petition for rehearing created by the National Council of Catholic Men.

Daniela Campos served as the editorial assistant for this podcast.

Susan Liebell is Dirk Warren '50 Professor of Political Science at Saint Joseph’s University in Philadelphia.