Law for the Prevention of Hereditarily Diseased Offspring
The Virginia statute which the ruling of "Buck v. Bell" supported was designed in part by the eugenicist Harry H. Laughlin, superintendent of Charles Benedict Davenport's Eugenics Record Office in Cold Spring Harbor, New York. Laughlin had, a few years previously, conducted a number of studies on the enforcement of sterilization legislation throughout the country and had concluded that the reason for their lack of use was primarily that the physicians who would order the sterilizations were afraid of prosecution by patients whom they operated upon. Laughlin saw the need to create a "Model Law" which could withstand a test of constitutional scrutiny, clearing the way for future sterilization operations. Adolf Hitler closely modeled his Law for the Prevention of Hereditarily Diseased Offspring on Laughlin's "Model Law". The Third Reich held Laughlin in such regard that they arranged for him to receive an honorary doctorate from Heidelberg University in 1936. At the Subsequent Nuremberg trials after World War II, counsel for SS functionary Otto Hofmann explicitly cited Holmes's opinion in "Buck v. Bell" in his defense.