Facts
- Oklahoma enacted the Habitual Criminal Sterilization Act (1935), authorizing involuntary sterilization of certain “habitual criminals” convicted multiple times of felonies involving “moral turpitude.”
- The Act provided a special court proceeding initiated by the Attorney General, with notice, counsel, and a jury determination limited to habitual-criminal status and whether the procedure could be performed without harm to general health.
- The Act excluded several offense categories from coverage, including embezzlement, violations of prohibitory laws, revenue offenses, and political offenses.
- Jack T. Skinner, an Oklahoma prisoner, had three felony convictions (including stealing chickens and robbery with firearms) and was targeted for sterilization under the Act.
- Oklahoma courts upheld the Act and ordered Skinner sterilized over his Fourteenth Amendment objections.
Issues
- Whether Oklahoma’s sterilization scheme violated the Fourteenth Amendment’s Equal Protection Clause by selecting some repeat offenders for sterilization while exempting other similarly punishable offenders.
- Whether sterilization’s permanent deprivation of the ability to procreate required especially close judicial review of statutory classifications.
Decision
- The Supreme Court unanimously reversed the state judgment ordering Skinner sterilized.
- The Court held the Act unconstitutional as applied because it created arbitrary and discriminatory classifications among criminals (notably treating larceny-type offenders differently from embezzlers).
- Because the law burdened procreation, a basic civil right, the State’s classifications required especially exacting review and lacked adequate justification.
- Concurring opinions emphasized that the irreversibility of sterilization also raised serious due process concerns and that courts were ill-suited to administer heredity-based penal categories.
Legal Principles
- Procreation is a basic civil right; laws permanently impairing it implicate a fundamental liberty interest.
- When a statute burdens a fundamental right, equal protection demands unusually careful examination of the State’s classification choices.
- A sterilization law violates equal protection when it irrationally treats similarly situated offenders differently without a defensible relation to the law’s asserted aims.
- The constitutional risk of state-imposed sterilization is heightened by its irreversibility and potential for discriminatory targeting, requiring rigorous judicial scrutiny.
Conclusion
The Court invalidated Oklahoma’s habitual-criminal sterilization regime as applied because it imposed an irreversible deprivation of procreative ability on some repeat offenders while exempting others without a rational, defensible basis, violating equal protection where a fundamental right was at stake.