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In a majority opinion written in 1927 for the Supreme Court case Buck v. Bell, Supreme Court Justice Oliver Wendell Holmes wrote that “if instead of waiting to execute degenerate offspring for crime, or to let them starve for their imbecility,” it would be “better” if “society can prevent those who are manifestly unfit from continuing their kind.” 

This case ushered in a form of legal sterilization into the U.S. After the Supreme Court deemed the practice constitutional, over 30 states adopted laws allowing for the legal forced sterilization of individuals society deemed “unfit” to reproduce. From 1924 to 1979, an estimated 8,000 people were sterilized in the Commonwealth of Virginia alone.

This infamous court case involved 17-year old Carrie Buck, a Charlottesville local. After Buck was assaulted and impregnated, the Supreme Court used the case as an opportunity to constitutionalize eugenic practices that were already occurring within Virginia. 

Holmes’ majority opinion reflects white America’s push to uphold a racial hierarchy through sentiments of biological inferiority, which included a wide range of supposed deficiencies from “feeble-mindedness” to physical inferiority. The...