After Carrie Buck, a 17-year-old white woman in North Carolina, was assaulted and became pregnant, her family blamed her for the assault and committed her to a psychiatric institution for "immorality, prostitution and untruthfulness," where she was sterilized.

This becomes the test case for the 1924 Virginia sterilization act, which promoted the sterilization of inmates "afflicted with hereditary forms of insanity, idiocy, imbecility and feeble-mindedness."

In Buck v. Bell, the U.S. Supreme Court upholds the legality of Buck's forced sterilization on the grounds that she "suffered from hereditary feeblemindedness" based solely on an examination of her family records, and the fact that she is the child of a sex worker. Justice Oliver Holmes explains the state’s interest in preemptively sterilizing people with "hereditary defects," saying, "It is better for all the world." In the years following the decision, the number of states with compulsory sterilization laws will grow to 30.