“Three Generations of Imbeciles are Enough” — The Case of Buck v. Bell

A newly digitized Supreme Court Case file can help students learn about the eugenics movement in the United States and its impact on one of the most infamous Supreme Court decisions: Buck v. Bell.

In his nearly 30 years in the Supreme Court, Justice Oliver Wendell Holmes, Jr. was known for his effective use of language in both his opinions and dissents. Considered by some scholars to be the finest philosophical mind and greatest legal scholar on the bench (and one of its most-cited members), his language in defense of free speech is noted for its eloquence and progressive thinking.

“If there is any principle of the Constitution that more imperatively calls for attachment than any other it is the principle of free thought—not free thought for those who agree with us but freedom for the thought that we hate.”
United States v. Schwimmer

“The most stringent protection of free speech would not protect a man in falsely shouting fire in a theatre and causing a panic.”
Schenck v. United States

His opinion in the case of Carrie Buck v. John Hendren Bell, Superintendent of State Colony for Epileptics and Feeble Minded stands in stark contrast with the phrase: “Three generations of imbeciles are enough.”


Underlined Selection from Justice Oliver Wendell Holmes Opinion in the case of Buck v. Bell

The supposed “imbecile” in question was Carrie Buck, by then a 21-year-old woman from Charlottesville, Virginia. At the age of 17, Carrie Buck became pregnant, which was later reported to have been the result of rape, allegedly by a relative of her foster parents. Following the birth of her child, Carrie was committed to the “Virginia Colony for Epileptics and Feeble-Minded” (the same institution that housed Carrie’s birth mother, Emma Buck) on the grounds of “feeble-mindedness.”

Around that time, Virginia’s legislature had just passed a new law calling for “the sterilization of mental defectives.” Passed during the height of the eugenics movement in the United States, this law stated that sterilization would promote “both the health of the individual patient and the welfare of society.”


Selection of Virginia Sterilization Act

The superintendent of the Virginia Colony, Dr. Albert S. Priddy, chose Carrie Buck to be the first test case of the legality of this new statute. In his filed Petition, Priddy evaluated her as “unfit to exercise the proper duties of motherhood” due to her “anti-social conduct and mental defectiveness.” However, he believed that if sterilized, her “good physical health and strength” meant she could leave the Colony and “enjoy the liberty and blessings of outdoor life [and] become self-supporting.”


Selection from the Petition of A.S. Priddy

After several hearings and state court decisions that upheld the Virginia law, Buck v. Bell (for Dr. John H. Bell, who succeeded Priddy as Superintendent following his death) reached the U.S. Supreme Court in 1927.

Selections from the recently digitized Supreme Court case, illustrating this ugly chapter in American history, are now available on DocsTeach. In addition to the infamous Supreme Court opinion from Oliver Wendell Holmes, Jr., the case includes a printed record of the earlier hearings, testimony, evidence, and decisions from the State of Virginia court system.

Among these earlier filings is a deposition from Harry Laughlin and testimony of A. H. Estabrook, both staff members of the Carnegie Institution’s Eugenics Record Office in Cold Spring Harbor, New York. In his deposition, Laughlin describes Carrie Buck and her family as part of the “shiftless, ignorant, and worthless class of anti-social whites of the South” whose  “feeblemindedness is caused by the inheritance of degenerate qualities.”


Selection from the Deposition of Harry Laughlin

Likewise, in his testimony, A.H. Estabrook describes in pseudo-scientific terms how feeble-mindedness is passed down generation to generation.

Buck_v_Bell_085 (1)

Selection from the Testimony of A.H. Estabrook

Several people who knew Carrie Buck directly also testified during the earlier court proceedings. Most of this testimony comes from doctors, nurses, and social workers. Anne Harris, a nurse from Charlottesville, describes in her testimony an incident involving Carrie passing notes in school of an “anti-social” character.


Selection from the Testimony of Anne Harris

Ms. Harris also describes Carrie’s mother Emma as “feeble-minded” and a “socially inadequate person” who was supported by charity, living in the worst neighborhoods and unable to support her children.

Several of the accounts included in the Supreme Court record from earlier proceedings come from people that had never actually met Carrie. A trio of teachers provided testimony about the behavior and aptitude of Carrie’s relatives (notably absent was testimony from any of Carrie’s teachers). In her testimony, Eula Wood, a teacher from Earlysville, Virginia, discusses Doris Buck, Carrie’s half-sister. Ms. Wood describes Doris as “dull in her books” and describes demoting her to first grade.

Virginia Landis, a teacher from Charlottesville, Virginia, is asked about a George Dudley, another relative of Carrie Buck. In her testimony, Virginia (who testified that she did not “know Carrie Buck at all”) describes George as “dull-minded” who was “slow in grasping things in school.”

Buck_v_Bell_059 (1)

Selection from Testimony of Virginia Landis

Likewise, another teacher, Virginia Beard, describes Roy Smith (Carrie’s supposed half-brother) as “below the grade of other boys his age” (he was currently in the 4th grade at the age of fourteen) and one who “tried to be funny–tried to be smart.”

Though these testimonies might sound irrelevant to the specific case of Carrie Buck, during the height of eugenics beliefs in the United States, this was evidence that proved Carrie’s condition was due to an inheritance of inferior traits. This and other similar details could let Justice Holmes state that three generations of imbeciles were enough.

Several months following Holmes’s opinion and the Supreme Court decision that upheld the Virginia Sterilization Act, Dr. John H. Bell performed Buck’s sterilization by salpingectomy (removal of the Fallopian tubes) on October 19, 1927. She was the first person involuntarily sterilized under Virginia’s law for the sterilization of persons considered “unfit.” An estimated 8,300 Virginians were sterilized under the state law, which was in effect until 1972.

Over 20 selections from this recently digitized Supreme Court case are now available by searching the phrase “Buck v. Bell” on DocsTeach.

This case file was recently digitized in the National Archives’ Innovation Hub due, in large part, to efforts by the National Archives employee affinity group “disABILITY.”

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The “Write” Stuff: Literacy, Writing, and Research Festival this July

The “Write” Stuff: Literacy, Writing, and Research Festival at the National ArchivesWe invite students, teachers, and families to join us — and some of your favorite authors and illustrators — for a free summer writing festival at the National Archives!

Students WritingFriday, July 7 and Saturday, July 8 we’ll host The “Write” Stuff with workshops and a family day at the National Archives Museum in Washington, DC.

Select events will be live-streamed or available via webinar for those who can’t make it in person.

Friday, July 7

Be a Writer Day for Participants in Grades 4-6, free admission, registration required

Join us in person, online through YouTube, or via webinar for an exciting day. Highlights include:

  • 10:30 am – noon: Discussion and Q&A with notable authors and illustrators of Young Adult and Children’s Literature: John Hendrix, Syl Sobel, Susan Campbell Bartoletti, Jacqueline Jules, and Tonya Bolden. Moderated by Kitty Felde, host of the podcast “Book Club for Kids.” Live-streamed on YouTube.
  • 12:15 – 12:45 pm: Book signings by featured authors
  • 2 – 4:15 pm: Author-led hands-on workshops. Read the list of breakout sessions on the registration pageThe session Making Fiction from Facts will be available via webinar. Registration required; participants will receive a link to join the webinar via email the week of the program.

To register, for more information, or to view author bios visit www.archivesfoundation.org/event/write-stuff

Saturday, July 8, 10 am to 4 pm

Family Research & Literacy Day, free admission and open to all

Join us for an exciting day. Highlights include:

  • Reading in the Learning CenterDiscover literacy and research organizations and their available resources.
  • Enjoy story times with special guest readers.
  • Participate in activities led by featured authors and illustrators Marty Rhodes Figley, Syl Sobel, Janet Macreery, Diane Kidd and Margaret A. Weitekamp, John Hendrix, Tim Grove, Tonya Bolden, and Kitty Felde.
  • Watch a live recording of the “Book Club for Kids” podcast with Kitty Felde, and special guest reader, NPR’s Susan Stamberg, with young readers from the Girlfriends Book Club Baltimore!
  • Meet featured authors and illustrators and get books signed.
  • View DC National History Day project finalists.


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Summertime Professional Development at our Presidential Libraries

This summer, join us for one of our professional development workshops for educators on using primary sources in the classroom.

The Harry S. Truman Library and Museum

Man in building

Dwellings at a labor camp in Mathis, Texas, ca. 5/1948 (Photograph 60-210-40 from the Truman Library)

“Truman, Migratory Farm Labor and Immigration”
June 26-30

Come to the Truman Library in Independence, MO, and research primary sources related to immigration as part of our Primarily Teaching summer institute. You’ll also create an online learning activity. Learn more and apply at www.archives.gov/education/primarily-teaching.

The $100 fee includes all materials. Graduate credit may be available for an additional fee. Participants will receive a stipend upon completion.

Eisenhower Presidential Library, Museum, and Boyhood Home

Plane Wreckage

Faked Soviet Photo to Show Complete Destruction of U-2 Plane, 1960 (Photograph 79-5-28 from the Eisenhower Library)

“U-2 Spy Plane Crisis and its Impact on U.S.-U.S.S.R. Relations”
July 17-21

Explore primary sources related to the U-2 spy plane crisis at the Eisenhower Library in Abilene, KS, as part of our Primarily Teaching summer institute. You’ll identify materials from the Library’s collections to add to our tool for teaching with documents, DocsTeach.org, and create an online learning activity. Learn more and apply at www.archives.gov/education/primarily-teaching.

The $100 fee includes all materials. Graduate credit may be available for an additional fee. Participants will receive a stipend upon completion.

Herbert Hoover Presidential Library and Museum

Elementary Summer Teacher Institute
July 24-29

Join the Herbert Hoover Presidential Library and Museum for a week of learning about American Presidents, Iowa Territorial Government, Iowa History, Voting, Citizenship, and how to incorporate primary sources into your elementary classroom. We will complete workshops geared towards understanding the new Iowa Social Studies Standards and incorporate them into building lesson plans and classroom activities. All teachers will submit an assignment for completion of graduate credit.

Applications are due May 1st. Learn more and apply at hoover.archives.gov/education/elementaryteacherworkshop.pdf (PDF)


Other PD from the National Archives

Please note that waitlist applications are being accepted for the Primarily Teaching summer workshop at the National Archives in Washington, DC (July 24-28) to explore women’s rights through archival materials.

Primarily Teaching workshops are made possible in part by the National Archives Foundation, through the support of Texas Instruments.

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New Gallery Packs for Students Visiting the National Archives Museum

Today’s post about a new activity for school-age visitors comes from Education and Public Programs intern Elise Paisant.

Gallery Pack ContentsAre you looking for a hands-on educational activity for your students to do while visiting the National Archives in Washington, DC?

Our new gallery packs, designed with students and families in mind, provide activities for each of our permanent museum exhibits. Students can even wear an archivist’s stack coat to complete their experience!

Groups of students, led by a chaperone, can use the packs to explore the museum and learn about the National Archives and the records we hold. Students will walk away with a stronger understanding of why we preserve Government records for the American people, and of our country’s formation.

Students in Records of RightsUsing the gallery packs, students will practice three main skills: observation, document analysis, and critical thinking.

The activities in the packs require students to look closely at our permanent exhibits and analyze for themselves the primary source documents that they see.

Each exhibit has multiple activities designed to engage students in hands-on learning. The activities in each pack include:

  • “Kids in the Archives” in the Record of Rights exhibit: Analyze primary sources from or about kids and reflect on how those documents influenced America.
  • “Kids in the Archives” in the Public Vaults exhibit: Analyze documents connected to kids and reflect on their impact.
  • Public Vaults Image Search: Use small detailed cropped segments of larger images to find the complete versions.
  • “Constitutional Quest” in the Public Vaults: Determine which primary source best matches up with parts of the Constitution’s preamble, then identify items from students’ own lives that also fit the theme.
  • Student in the RotundaFaulkner Murals in the Rotunda: Learn about a few of the men involved with the creation of the Declaration and Constitution.
  • “Parchment and the Big Three” in the Rotunda: Learn about the materials that our founding documents were written on and how they are preserved at the National Archives.
  • Letter to the President in the Public Vaults: Examine letters to the President and write a letter on provided National Archives stationary to take home and mail.
  • Museum Manners Guide: Learn and practice great museum behavior while looking for related documents in our exhibit spaces.

Gallery Packs in the Learning CenterWhile some activities appear oriented for older students, most can be modified to accommodate younger students.

Your students can begin their archival adventure today using our gallery packs! Pick them up in our Boeing Learning Center, open Monday-Saturday from 10 a.m. to 4 p.m. A group chaperone must provide a driver’s license in order to check them out.

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Meet Our New Document Analysis Worksheets!

Photo Analysis WorksheetDocument analysis is the first step in working with primary sources. Our worksheets can help teach your students to think through primary source documents for contextual understanding and to extract information to make informed judgments.

We have worksheets for several media types, available on our website:

  • photos,
  • written documents,
  • artifacts,
  • posters,
  • maps,
  • cartoons,
  • videos, and
  • sound recordings.

Have you used any of our document analysis worksheets before? We originally created these student tools many years ago — and thousands of educators have made use of them.

Now we’re happy to report that we’ve made some updates. Not only do the sheets have a new look, but they reinforce a standard progression while guiding students through the analysis process:

  • Meet the document.
  • Observe its parts.
  • Try to make sense of it.
  • Use it as historical evidence.


Worksheets for Novice or Younger Students, or Those Learning English

Written Document Analysis WorksheetWe’re also happy to announce that we’ve created some brand new worksheets to join the existing group!

This set covers all the same document types — but the worksheets are geared to the early grades or those very new to the process. They guide students with simple language, answer choices, and colorful illustrations.

Progressing Beyond the Worksheets

We hope the worksheets will teach your students to analyze primary sources independently so that — ultimately —they won’t even need them anymore!

The first few times you ask students to work with primary sources, and whenever you have not worked with primary sources recently, model careful document analysis using the worksheets. Point out that the steps are the same each time.

Once students have become familiar with using the worksheets, direct them to analyze documents as a class or in groups without the worksheets, vocalizing the four steps as they go.

Eventually, students will internalize the procedure and be able to go through these four steps on their own every time they encounter a primary source document. Remind students to practice this same careful analysis with every primary source they see.

Don’t stop with document analysis though! Analysis is just the foundation. Move on to activities in which students use the primary sources as historical evidence, like those on DocsTeach.org, our online tool for teaching with primary sources.

Please let us know if you have feedback on these new, or newly updated, worksheets! Leave a comment below or send us an email. We’d love to hear from you.

These worksheets and other materials created by the National Archives and Records Administration are in the public domain — you can copy, modify, and distribute them.

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Upcoming PD Webinar: Bringing Native American Voices into Your Classroom

Man standing in front of tepees

“Chief Young Man Afraid of His Horses and his tepee taken at Pine Ridge Agency [Sioux],” 1/17/1891; from the Records of the War Department General and Special Staffs; available on DocsTeach.

Join us for a free professional development webinar on Thursday, April 6th at 7 p.m. or 10 p.m. EDT to learn about bringing Native American viewpoints and primary sources into your lessons.

We will share several simple ways to bring Native American stories, viewpoints, and primary sources into your students’ lives.

Learn about what is already created that you can just drop into your regular lessons — and what is coming in the near future.

The workshop will focus on lessons, primary sources, and examples from the Pine Ridge and Standing Rock Sioux. Everyone is welcome, however, no matter where you are!

We offer a one-hour National Archives Professional Development certificate for attending. Some school districts and libraries accept these certificates for required PD credit. Be sure to check with your district in advance.

To register, email us at distancelearning@nara.gov

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New “Remembering WWI” App Release!

Women's Machine Gun Squad

Women’s Machine Gun Squad Police Reserves, New York City (Photograph 165-WW-143B-23, from the Records of the War Department General and Special Staffs, available at https://catalog.archives.gov/id/31474833)

We’ve launched Remembering WWI, an iPad and Android app for exploring, collaborating, and engaging with our extensive collection of WWI photographs and moving images. The app commemorates the 100-year anniversary, in April 2017, of the U.S. entry into World War.

It is now available in the iTunes and Google Play stores.

The National Archives, together with our partners at Historypin, is leading this national collaborative effort with participation from the Library of Congress and National Museum of American History, Smithsonian Institution, the WWI Centennial Commission, the American Association for State and Local History, and the National WWI Museum and Memorial.

The app invites people nationwide to contribute their own stories and play a part in the centennial commemoration of the First World War. Building on an amazing moving image and photographic archive being digitized and preserved as part of a larger Wartime Films Project, the app features thousands of rarely seen public domain images and films to encourage discovery and creative reuse.

Intended in part for classroom instruction, Remembering WWI provides educators with the digital sources and narrative-building tools to help students foster an understanding of World War I.

Collections within the app.

Explore thematic collections in the app.

Using the archival content within the app, you can create your own collections and build and share new narratives around the people, events, and themes you’re exploring. Thematic collections from the National Archives, the Library of Congress, and the Smithsonian are featured to serve as inspiration or starting points for content discovery and reuse.

Film clips within the app

You can pull film clips into collections within the app.

Items in the WWI app

Add any item to a collection within the app, or create a new collection using that item.

Collection edit page in the WWI app

Get started on the collection edit page by adding a Collection title and chapter, then add app items or additional chapters using the button at the bottom of the page.

Educators are one of our primary audiences for this app, and we are grateful for those who participated in our user-design sessions and helped influence how this WWI app will be used in classrooms across the country.

To connect with other educators using the app, or discuss methods for using the app in the classroom, visit our History Hub. You can also ask general questions, report bugs, and find additional resources.

DocsTeach WWI pageAnd visit our special WWI page on DocsTeach to find, and even download, many of the photos and videos included in the app, plus many more. Browse primary sources by topic or access online teaching activities related to WWI.

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Primarily Teaching Summer Workshop for Educators

Teachers study recordsThis summer, join us for one of our Primarily Teaching workshops for educators on using historical documents in the classroom.

We’ll conduct research with original documents in the holdings of the National Archives and Presidential Libraries. Discover some of those incredible teachable documents that help educators and students unlock the past.

You will explore a specific topic that fits within the theme Conflict and Compromise, researching primary sources like letters, reports, petitions, case files, photographs, and more. (Conflict and Compromise in History is the National History Day (NHD) 2018 theme. Participation in NHD is not required.)

  • Migratory Farm Labor and Immigration at The Harry S. Truman Library and Museum in Independence, MO, June 26-30
  • U-2 Spy Plane Crisis and its Impact on U.S.-U.S.S.R. Relations at the Eisenhower Presidential Library, Museum, and Boyhood Home, July 17-21
  • Women’s Rights at the National Archives in Washington, DC, July 24-28

Worker and Flag BearerYou will identify between 3 and 5 items (documents, photos, maps, etc.) to digitize and make available online. We will add these to our online tool for teaching with documents— DocsTeach.org—while you’re onsite. During the workshop, you’ll produce a DocsTeach learning activity using these digitized primary sources.

The $100 fee includes all materials. Graduate credit from a major university may be available for an additional fee. Participants will receive a stipend upon successful completion of the course.

Apply no later than six weeks before the workshop. Participation in each session is limited to 10 members. Classes will be filled on a first-come, first-served basis.

Learn more and apply at: www.archives.gov/education/primarily-teaching


Archival Images:

  • Top – Inside one of the one-room shack dwellings at a labor camp in Mathis, Texas, ca. 5/1948 (Photograph 60-210-40 from the Harry S. Truman Library).
  • Bottom – Flag Bearer for Women’s Rights Standing Near White House, ca. 1920 (Photograph 306-N-70-2641 from the Records of the U.S. Information Agency at the National Archives).


Primarily Teaching workshops are made possible in part by the National Archives Foundation, through the support of Texas Instruments.

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Upcoming PD Webinar: Teaching the Constitution with Political Cartoons

Join us in a free Share My Lesson webinar on March 16th at 7 p.m. EDT to learn about teaching the Constitution using political cartoons.

Uncle Sam driving horses

“This Is the Team That Will Win Every Time,” showing a three-part team made up of the House of Representatives, Senate, and Executive leading the way to victory, 3/27/1898. From the Records of the U.S. Senate. (Available at www.docsteach.org/documents/document/this-is-the-team-that-will-win-every-time)

Clifford K. Berryman was a cartoonist in Washington, DC, from the 1890s to 1949. A collection of 2,400 original pen-and-ink drawings by Berryman from the U.S. Senate Collection is housed at the Center for Legislative Archives, a part of the National Archives.

During this interactive professional development webinar:

  • Discover how the political cartoons of Clifford K. Berryman can engage students with the U.S. Constitution.
  • Explore how the “Big Ideas” of the Constitution are represented in Berryman’s illustrations.
  • Practice techniques for analyzing political cartoons in the classroom and learn about additional resources from the National Archives.

Register for Free.

One hour of PD credit is available.

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Primary Source Highlights on DocsTeach

We’re constantly updating DocsTeach.org — the online tool for teaching with documents from the National Archives. Here are some recent highlights.

Newly Added Primary Sources

Actors watching

Hollywood Ten – We recently added court documents related to the screenwriters, producers, and directors who jeopardized their careers by taking a stand against the House Un-American Activities Committee (HUAC). Several court cases, including Dalton Trumbo v. Loew’s Inc., show the ten suing their employers for breach of contract.

Image: Members of the “Hollywood Committee for the First Amendment,” including Humphrey Bogart and Lauren Bacall, watch HUAC hearings (Dalton Trumbo v. Loew’s Incorporated, from the Records of District Courts of the United States)

Building with people in front

The Cowen Report – In 1906, the U.S. Government sent immigration inspector Philip Cowen on an undercover mission to Russia to discover the cause of increased Jewish immigration. His findings revealed persecution of Russian Jews, difficult living conditions, economic hardship, and, most tragically, pogroms – targeted attacks on Jews. Read more about his investigation in a recent blog post.

Image: Building with rifle shots, smashed windows, and fire damage (Cowen Report – European Investigation Entry No. 9, from the Records of the Immigration and Naturalization Service)

Staff Favorites

We asked our staff to pick a can’t-miss document on DocsTeach. Jenny Sweeney, education specialist at the National Archives at Fort Worth, couldn’t choose just one!

ListHere are a few compelling primary sources that she likes to share with teachers.

Do you have a favorite? We’d love to hear from you in the comments below or at docsteach@nara.gov!

What Docs should we add?

Every month the National Archives adds thousands of newly digitized primary sources to the main online catalog. We search through these additions to find those incredible teachable documents that help educators and students unlock the past to add to DocsTeach.

Would you like a say in what we add? Here are some recently digitized collections in our catalog. If you find something that you think your students (and others around the world) would benefit from, let us know. Comment below or send us the URL or the “National Archives Identifier” number.

President Reagan at DeskVideos from the White House Television Office during the Reagan Administration – Coverage includes speeches and remarks, Oval Office visits, bill signings, ceremonies, press conferences, Heads of State visits, trips, Inaugural events, campaign rallies, and Republican National Conventions.

Woman salutingWorld War II Foreign Posters – Produced by foreign information offices and war relief associations in the United States, the posters cover topics such as: children, conservation, employment, victory bonds, black markets, propaganda, recruitment, the Red Cross, sabotage and safety and security.

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