In Three Generations, No Imbeciles: Eugenics, the Supreme Court, and Buck v. Bell, Paul A. Lombardo argues that a small, zealous faction of the eugenics movement pushed for sterilization laws by exploiting Carrie Buck in a court case (Buck v. Bell) designed to set a precedent for the constitutionality of sterilization laws and protect practicing members of the eugenics community from prosecution. Lombardo successfully uses the narrative of the 1927 Buck v. Bell case to tie together different arguments and topics relating to the legal, political, and scientific (or lack of scientific) history of the eugenics movement and then shifts from the story of Buck v. Bell to its implications in current legal history.

Lombardo clearly places importance on the book as telling the “story” of Carrie Buck and the eugenics movement as he specifically uses the word “story” several times in the introduction and epilogue. This emphasis on story guides the emphasis and the structure of the book. Lombardo does not limit the emphasis of Three Generations, No Imbeciles to the legal history of Buck v. Bell, but rather covers the legal and political history of sterilization laws, the interpersonal connections and findings of the eugenics movement, and the controversy surrounding “scientific” eugenic claims. This multi-faceted approach to the book emphasizes the full story, rounding out relatively minor characters to Buck v. Bell, such as the witnesses called to the stand in the original trial or the wife of Aubrey Strode, and gives context to the case and court decision. This context, which Lombardo establishes by rich detail, proves his arguments. For example, it seems unimportant and off-topic when Lombardo first goes into detail about Strode’s second wife, Louisa Hubbard, in the chapter dedicated to the Virginia sterilization law. Lombardo later weaves in this thread showing that one of Strode’s star witnesses, Arthur Estabrook, was personally close, perhaps even unprofessionally so, with Louisa Hubbard. This detail serves as evidence for Lombardo’s argument that the advocates of the sterilization laws were closely connected and dedicated to helping advance the eugenic movement, even though some of them were not as pure or innocent as they wanted society to be. Similarly, Lombardo provides ample examples of how the arguments that Strode presented in defense of the sterilization law were at odds with the opinions of others in the eugenics movement. These examples prove that the arguments Buck v. Bell were based on were faulty, outdated, and controversial.

Following the story-based approach to the book, Lombardo organizes first topically, then chronologically. Before he discusses Carrie Buck and the court case, he first explores key elements of the eugenics movement including the idea of problem families, the role of hereditary characteristics, surgeries and sterilization, and Harry Laughlin’s influential publication on eugenics. Lombardo then switches to a more chronological structure for the remainder of the book, examining Buck v. Bell from its conception as a test case to its importance in the post-war thinking on eugenics and current legislation and jurisprudence on reproductive and privacy rights. The switch in structure is effective. It allows Lombardo to first establish several sets of topical evidence, which he then uses to dismantle the sham trial of Carrie Buck and the reactions to the Supreme Court decision. Lombardo dismantles the disproven claims that Carrie and her daughter were feebleminded and demonstrates that Justice Oliver Wendell Holmes reuses much of the cliched eugenicist language in his decision for the Court.

With one notable exception, the chapters of Three Generations, No Imbeciles are tightly focused, which facilitates the switch from topical to chronological structure by specifying the main point of each chapter. These focused chapters allow Lombardo to establish different reference points that he then comes back to when proving the various arguments inherent to his thesis. The one chapter that gets off topic is chapter 15, “Sterilizing Germans,” when Lombardo ends the chapter with a “where are they now” of Charles Davenport, Emma Buck, and Irving Whitehead and Aubrey Strode. This section is important to the book overall, but is misplaced here in a chapter focusing on the influence of American eugenics and Buck v. Bell on German eugenics and social engineering.

Lombardo’s use of primary sources (supplemented as needed by secondary sources) plays a key part in telling the story of Carrie Buck and in proving his thesis. One of the main arguments of his thesis is that the group pushing for the sterilization laws was a small, closed group zealously trying to accomplish its goals. He pays close attention to the language used by eugenicists throughout the topical chapters of the book and then pinpoints how Strode and Holmes use the same language in their writings and arguments on Buck v. Bell. Lombardo frequently uses quotes from primary sources to define terms such as “eugenics,” “germ plasm,” “feebleminded,” and the “defective, dependent, and delinquent classes.” Using eugenicists’ own words to describe their ideas and reasoning provides a better glimpse into the mind of such people and gives better context for the Buck trial. Lombardo’s analysis of the language used by Holmes’ writing on Buck v. Bell similarly points to the recycled terms and language used by eugenicists and points to the narrowness and zealousness of the group and its impact in legalizing sterilization laws.

Lombardo’s narrative approach affects not only the emphasis and structure of Three Generations, No Imbeciles, but also the voice and narration of the book. Lombardo inserts himself into the narrative in the introduction, last chapter, and epilogue as he explains how he came to be interested in the story of Carrie Buck and how he interacted with the story as it was “rediscovered” in the 1980s. While this first-person narration of a piece of historical analysis is unusual and a bit jarring in places, such as the paragraph about Carrie’s funeral when Lombardo says, “Twelve people witnessed her burial…I also looked on,” Lombardo’s choice to include himself in the narrative is consistent with the story-focused tone of the book and does not ultimately distract from the historical work he is doing. Rather, his insertion of self strengthens his arguments as to why Buck v. Bell is relevant to this day by adding a personal voice to the shock upon discovering the case and serves to contrast his work in telling Carrie Buck’s story to the shoddy defense of her lawyer Irving Whitehead.


Lombardo, Paul A. Three Generations, No Imbeciles: Eugenics, the Supreme Court, and Buck v. Bell. Baltimore, Maryland: John Hopkins University Press, 2010.