Carrie Elizabeth Buck was born in Charlottesville on July 2, 1906, the daughter of Frank W. Buck, a tinner, and Emma A. Harlow Buck. Her father died when she was very young. In April 1920 her mother was committed to the Virginia State Colony for Epileptics and Feeble-Minded in Lynchburg with a diagnosis of feeblemindedness, a vague term that was less a medical finding than a reflection of the examiners’ distaste for her sexual behavior. Carrie Buck had been removed from her mother’s care when she was three and placed with a foster family. She attended local schools, where her records indicate normal progress each year, but before she completed sixth grade her foster family withdrew her to perform housework for them.
In 1923 Carrie Buck became pregnant, by her account as the result of rape committed by a nephew of the foster family with whom she had lived for almost fourteen years. Believing that the pregnancy was evidence of promiscuity and thus of feeblemindedness, the foster family sought to have her committed, like her mother, to the Virginia State Colony for Epileptics and Feeble-Minded. At a hearing on January 23, 1924, Buck was adjudged epileptic and feebleminded. Following the birth on March 28, 1924, of an illegitimate daughter, Vivian Alice Elaine Buck, Buck entered the colony in Lynchburg on June 4. Her former foster family took her infant daughter into their home and gave her their name.
Shortly after Buck’s commitment, Albert S. Priddy, superintendent and physician at the colony, selected her to be the subject of the test case for the constitutionality of Virginia’s recently enacted involuntary sterilization statute. This law provided that the state could sterilize anyone found to be incompetent because of alcoholism, epilepsy, feeblemindedness, insanity, or other factors. Behind the law was the eugenic assumption that these traits were hereditary and that sexual sterilization could thus prevent their transmission. Uncertain that the new law could withstand a constitutional challenge, the framers and supporters of the law arranged to test it in court. They chose Buck in the belief that she had inherited her feeblemindedness from her mother and that her daughter showed signs of slow mental development as well.
The litigation went to circuit and appeals courts in Virginia, where the judges approved Buck’s sterilization. Eventually styled Buck v. Bell (referring to John H. Bell, the superintendent of the Virginia colony following Priddy’s death in 1925), the case went on to the United States Supreme Court in April 1927. On May 2 of that year the court ruled that Virginia’s law was constitutional and that Buck should be sterilized. In the majority opinion Justice Oliver Wendell Holmes enthusiastically declared that the “principle that sustains compulsory vaccination is broad enough to cover cutting the Fallopian tubes.” In an oft-quoted phrase, he concluded that “three generations of imbeciles are enough.” Consequently, Buck and approximately 8,300 other Virginians, including her younger half sister, were sterilized under the state law between 1927 and 1972.
After being surgically sterilized on October 19, 1927, and released from the Virginia colony to work for a family in Bland County, Buck married William D. Eagle, a widowed carpenter, on May 14, 1932. A quarter-century after his death on July 23, 1941, she married Charles A. Detamore, of Front Royal, on April 25, 1965. Friends, relatives, and professionals who knew her later in life deny the accuracy of her diagnosis as mentally retarded. She was independent and a helpful person to others for most of her life. Carrie Buck Eagle Detamore died on January 28, 1983, in a nursing home in Waynesboro and was buried in Oakwood Cemetery in Charlottesville. Vivian Dobbs, the daughter from whom she was separated shortly after giving birth, is buried on an adjacent hillside. Belying Justice Holmes’s famous opinion, Dobbs was an honor student when she died of enterocolitis on July 3, 1932, at age eight. The practice of involuntary sterilization did not cease in Virginia institutions until 1972, and the enabling act remained on the books until April 1974.
