Virginia repealed the law in 1974 and in 2002 apologized to its victims. However, Skinner v. In 2001, the Eighth Circuit Court of Appeals, citing Holmes’ decision, ruled that “involuntary sterilization is not always unconstitutional.”More recently, 150 inmates were sterilized without their consent in California prisons between 2006 and 2010.
At the Nuremberg Trials, Nazi defendants cited Buck v. Bell in their own defense.
Buck v. Bell has not been expressly overturned. In fact, Adolf Hitler cited Buck v. Bell as a model for his forced sterilization law to prevent “hereditarily diseased offspring.” The Nazis even used Buck v. Bell as a defense during the Nuremburg trials following World War II. Buck v. Bell has never been overturned by the Supreme Court. The opinion was never overturned and led to a marked increase in sterilizations across the United States.
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