Skinner v. Oklahoma ex rel. Attorney General

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Skinner v. Oklahoma ex rel. Attorney General by Mind Map: Skinner v. Oklahoma ex rel. Attorney General

1. Facts

1.1. Parties

1.1.1. Plaintiff - Jack Skinner

1.1.2. Defendant - State of Oklahoma ex rel. Williamson, Attorney General of Oklahoma

1.2. What Happened

1.2.1. The State of Oklahoma's Criminal Sterilization Act allowed the state to sterilize someone convicted two or more times of crimes "amounting to felonies involving moral turpitude". If it is found that the defendant is a "habitual criminal" then the court was able to order them sexually steralized In 1926, Skinner was convicted of stealing chickens. He was convicted of two subsequent robbery charges over the next 8 years. In 1935, the Criminal Sterilization Act was enacted and a year later, proceedings against Skinner were brought with the State's intended purpose of performing a vasectomy on Skinner.

1.3. Procedural History

1.3.1. In 1936, Skinner was prosecuted under the Sterilization Act and a jury found that sterilization was the proper charge. During his trial at the Oklahoma state court, the jury was instructed to “only consider if a vasectomy would be detrimental to [his] health”. The Supreme Court of Oklahoma affirmed the previous court’s decision and directed that a vasectomy be performed on Skinner. The United States Supreme Court then granted certiorari.

2. Rule of Law

2.1. Is barring someone from having offspring an unconstitutional act as protected by the Fourteenth Amendment?

2.2. Is the Equal Protection Clause violated by grouping certain types of individuals - those "involving moral turpitude" - together and discriminating against them?

2.3. Are the actions of this Act considered cruel and unusual punishment?

3. Analysis/Application

3.1. Plaintiff

3.1.1. Arguments - the plaintiff argues that the Due Process and Equal Protection Clause of the Fourteenth Amendment is violated as he was not given an opportunity to be heard on whether he could be a parent of a potentially socially-positive child. The plaintiff also argues that sterilization should be considered cruel and unusual punishment.

3.2. Defendant

3.2.1. Argument - the defendants would argue that the Habitual Criminal Sterilization Act is legal as it sought to effectively strip the gene pool of persons who had been convicted multiple times of "felonies involving moral turpitude".

3.3. The Court

3.3.1. The court's decision discusses how the Act takes away "one of the basic civil rights of man" (the right to bear a child). Going so far as to say "marriage and procreation are fundamental to the very existence and survival of the race".

3.3.2. The court rules that strict scrutiny of this case is necessary as the issue at hand is depriving someone of a fundamental right as the sterilization law does.

3.3.3. The court used Oklahoma's laws as to how they differentiate the punishments for similar charges larceny by fraud and embezzlement as evidence that the plaintiff's equal protection rights had been infringed upon. Treating crimes different did in fact violate the Fourteenth Amendment.

3.3.4. From a social policy perspective, the court made it's opinion known that it was against the eugenic inspired Act as neither scienceor knowledge allowed someone to know if criminal traits are genetically inheritable.

4. Conclusion

4.1. The Court held that the Act violated the Equal Protection Clause of the Fourteenth Amendment.

5. Impact

5.1. US v Miller - Defendant tried to dismiss indictment against him for being a felon in possession of a firearm by claiming that his Due Process and Equal Protection Clauses were violated by being discriminated against as a felon. Skinner v Oklahoma is cited as a case where it is explicitly stated that "disproportionate punishment for similar criminal offenses, by itself, would not offend the Constitution". This was applied to this case as the right to bear arms is not on equal footing with fundamental rights such as the right to bear offspring.

5.2. US v Williams - Defendant was convicted of arson and mail fraud. On his appeal, defendant used Skinner v Oklahoma to demonstrate how he believed his Equal Protection was violated as he was not protected as a first time offender. The ruling judge stated that the defendant's use of this case "is of no avail and indeed even cuts against him" as the defendant's equal protection challenge did not concern a basic civil right as it did in Skinner v Williams and thus not subject to strict scrutiny.

6. Importance

6.1. 1. A healthcare professional in 1942 would have a significant interest in the outcome of this case as it would impact the future of the vasectomy and sterilization business.

6.2. 2. From a bigger picture perspective, the decision in this case could impact the future of all government-mandated health procedures. If the Supreme Court were to rule that the Act were constitutional, it could open the door for other states to enact similar legislation to require a certain medical procedure. If the SC were to rule the Act unconstitutional, it gives more protection to the patient regardless of their criminal status.

7. Influence

7.1. Had the SC's decision gone the other way, it could have opened the door for state's to enact similar legislation for state-mandated medical procedures. If that were the case, there were presumably be a significant increase in medical lobbying firm's attention to pushing this type of legislation as it could mean more medical procedures financially backed by the state or federal government. There may also have been more vasectomy trained doctors over the past few decades had the decision been different.

7.2. The sexual contraceptive industry has been impacted by this ruling as potential customers have not been taken off the market by state-mandated vasectomies. To that end, hospitals, mid-wives, and other professions associated with birthing have been positively impacted by this ruling as they would presumably had less deliveries over the past 75 years had the ruling been different.

8. Issue

8.1. The issue before the Supreme Court is whether the Due Process and Equal Protection Clause of the Fourteenth Amendment renders the Sterilization Act unconstitutional for depriving Skinner of his right of life, liberty, and property without due process by rendering him sterile and unable to produce offspring.