The Supreme Court case of Buck vs. Bell ruled that mentally retarded women must undergo sterilization to ensure they could not get pregnant. This decision was made in the hopes of limiting the number of people born with such disabilities.

The case wasn't overturned until the 1970s, when a mother had forced sterilization of her "slightly" retarded daughter. It was found that this girl should not have had the mandatory procedure, calling into question the subjective nature of the law.