In the 1926 case of Buck v. Bell, the U.S Supreme Court upheld a Virginia statute that allowed for the sterilization of individuals deemed unfit to procreate. The case was brought by Carrie Buck, who had been committed to a state institution after being declared feeble-minded and promiscuous following an out-of-wedlock pregnancy. She challenged her impending sterilization as unconstitutional under the Fourteenth Amendment's Due Process clause which guarantees all citizens equal protection under law. However, in an 8-1 decision written by Justice Oliver Wendell Holmes Jr., the court ruled against Buck stating that society could prevent those who are manifestly unfit from continuing their kind and thus protect public health and welfare. This ruling effectively legitimized eugenic sterilization laws in America until they were gradually repealed during mid-20th century.

In the case of Buck v. Bell, there was no official dissenting opinion recorded as the decision was made by an 8-1 majority in favor of upholding Virginia's sterilization law. However, Justice Pierce Butler dissented without writing a separate opinion. If he had written one, it might have argued against forced sterilization on grounds of personal liberty and bodily autonomy or questioned whether such procedures genuinely served public health interests. It could also have raised concerns about potential misuse for eugenic purposes or discrimination against people with mental disabilities.