ABSTRACT
In 1924, Virginia passed a law that legalized the practice of sterilizing persons in mental institutions, and three years later, in Buck v. Bell, 272 US 200 (1927), the US Supreme Court upheld the law. Its opinion promoted views closely akin to social Darwinism, the extension of Charles Darwin's theory of natural selection, or "survival of the fittest," to the social arena. Under the law, mental institutions followed specific procedures for the sterilization of patients. The superintendent recommended sterilization of a patient to the board of directors and then informed the patient and the patient's guardian of the decision. The year Virginia passed the law, an eighteen-year- old institutionalized woman brought her case to the Virginia Circuit Court, challenging its constitutionality. Carrie Buck's guardians had placed her in the Virginia State Colony for Epileptics and FeebleMinded after she was raped. Carrie gave birth to a daughter while living in the institution, where her mother also resided.
