Thirteen Ways of Looking at Buck v. Bell: Thoughts Occasioned by Paul Lombardo’s Three Generations, No Imbeciles

Michelle Oberman, Santa Clara University School of Law

Abstract

Paul Lombardo’s recent book, Three Generations, No Imbeciles: Eugenics, the Supreme Court and Buck v. Bell, 1 chronicles the history of state-sponsored sterilization over the course of the 20th century. As a historical endeavor, it is rich and rewarding, permitting the reader a broad understanding of the social, cultural and legal context for the case that inspired Oliver Wendell Holmes’ famous quotation, “Three generations of imbeciles are enough.”2 Lombardo’s work masterfully ties the eugenics movement of the early 20th century to the broader policies informing the government’s role in regulating reproduction.