Facts
- Virginia enacted a 1924 statute authorizing sterilization of certain institutionalized persons diagnosed with hereditary “insanity, imbecility, etc.” through specified surgical procedures.
- Carrie Buck, a young woman committed to the Virginia State Colony for Epileptics and Feeble Minded, was selected as a test case to validate the statute.
- The superintendent sought to sterilize Buck on the asserted ground that Buck, her mother (also institutionalized), and Buck’s infant daughter had a hereditary “feeble-mindedness.”
- The statute required an administrative process with notice, a hearing, representation by a guardian, and appellate review in state courts before sterilization could be performed.
- A Virginia circuit court authorized the superintendent to perform a salpingectomy on Buck to render her sterile, and the Virginia Supreme Court of Appeals affirmed.
Issues
- Whether Virginia’s sterilization statute, as applied to Carrie Buck, deprived her of liberty without due process of law under the Fourteenth Amendment.
- Whether limiting sterilization authorization to inmates of specified state institutions denied equal protection by excluding similarly situated persons outside those institutions.
Decision
- The U.S. Supreme Court affirmed, upholding the statute and the order authorizing Buck’s sterilization (8–1).
- The Court held that the statute’s procedures—notice, hearing, representation, and judicial review—satisfied due process.
- The Court held that restricting the law’s application to institutional inmates did not violate equal protection because the state could treat that group as a class and proceed incrementally.
- Justice Butler dissented without opinion.
Legal Principles
- A state may authorize compulsory sterilization of certain institutionalized persons if the law provides procedural protections sufficient to satisfy Fourteenth Amendment due process.
- Equal protection is not necessarily violated when a statute targets a defined class within the state’s regulatory reach (here, institutional inmates), even if others outside that class are not covered.
- Legislatures may address perceived social problems in stages and are not required to regulate all comparable situations simultaneously.
Conclusion
The Court sustained Virginia’s compulsory sterilization scheme as a valid exercise of state power, concluding that the statute’s procedural safeguards met due process requirements and that confining the program to institutionalized persons did not constitute unconstitutional discrimination under the Equal Protection Clause.