By 1924, approximately 3,000 people had been involuntarily sterilized in America; the vast majority (2,500) in California. That year Virginia passed a Eugenical Sterilization Act based on Laughlin’s Model Law. It was adopted as part of a cost-saving strategy to relieve the tax burden in a state where public facilities for the "insane" and "feebleminded" had experienced rapid growth. The law was also written to protect physicians who performed sterilizing operations from malpractice lawsuits. Virginia’s law asserted that "heredity plays an important part in the transmission of insanity, idiocy, imbecility, epilepsy and crime…" It focused on "defective persons" whose reproduction represented "a menace to society."

Carrie Buck, a seventeen-year-old girl from Charlottesville, Virginia, was picked as the first person to be sterilized. Carrie had a child, but was not married. Her mother Emma was already a resident at an asylum, the Virginia Colony for the Epileptic and the Feebleminded. Officials at the Virginia Colony said that Carrie and her mother shared the hereditary traits of "feeblemindedness" and sexually promiscuity. To those who believed that such traits were genetically transmitted, Carrie fit the law’s description as a "probable potential parent of socially inadequate offspring." A legal challenge was arranged on Carrie’s behalf to test the constitutional validity of the law. At her trial, several witnesses offered evidence of Carrie’s inherited "defects" and those of her mother Emma. Colony Superintendent Dr. Albert Priddy testified that Emma Buck had "a record of immorality, prostitution, untruthfulness and syphilis." His opinion of the Buck family more generally was: "These people belong to the shiftless, ignorant, and worthless class of anti-social whites of the South." Although Harry Laughlin never met Carrie, he sent a written deposition echoing Priddy’s conclusions about Carrie’s "feeblemind-edness" and "moral delinquency." Sociologist Arthur Estabrook, of the Eugenics Record Office, traveled to Virginia to testify against Carrie. He and a Red Cross nurse examined Carrie’s baby Vivian and concluded that she was "below average" and "not quite normal." Relying on these comments, the judge concluded that Carrie should be sterilized to prevent the birth of other "defective" children. The decision was appealed to United States Supreme Court. Justice Oliver Wendell Holmes Jr., himself a student of eugenics, wrote the formal opinion for the Court in the case of Buck v. Bell (1927). His opinion repeated the "facts" in Carrie’s case, concluding that a "deficient" mother, daughter, and granddaughter justified the need for sterilization. The decision includes the now infamous words: It is better for all the world, if instead of waiting to execute degenerate offspring for crime or to let them starve for their imbecility, society can prevent those who are manifestly unfit from continuing their kind…Three generations of imbeciles are enough. Recent scholarship has shown that Carrie Buck’s sterilization was based on a false "diagnosis" and her defense lawyer conspired with the lawyer for the Virginia Colony to guarantee that the sterilization law would be upheld in court. Carrie’s illegitimate child was not the result of promiscuity; she had been raped by a relative of her foster parents. School records also prove that Vivian was not "feebleminded." Her 1st grade report card showed that Vivian was a solid "B" student, received an "A" in deportment, and had been on the honor roll.