Skinner v. Oklahoma

1. Facts

1.1. Parties: Oklahoma courts which enacted the statute in question; Skinner-original defendant in case of stealing chickens; Supreme Court

1.2. Background: In 1926, Skinner was convicted of stealing chickens and armed robbery (twice) was sentenced to jail. During his imprisonment, Oklahoma's Criminal Habitual Sterilization Act was passed, and he was sentenced to undergo sterilization. He challenged the Act as unconstitutional under the 14th Amendment. The Supreme Court allowed the vasectomy to be performed in a 4-5 decision.

1.3. Procedural History: The statute in question separates different types of "stealing" into categories punishable with federal sterilization or not punishable with sterilization. The statute was aimed at using eugenic approaches to eliminating undesirable traits from the gene pool.

2. Rule

2.1. 14th Amendment

2.2. Oklahoma's Crimnial Habitual Sterilization Act

3. Conclusion

3.1. The Supreme court reversed the ruling, holding that the Oklahoma statute was unconstitutional under the 14th and 8th Amendments.

3.2. Persons have the right to not be federally sterilized for crimes of theft.

4. Application

4.1. How would the plaintiff argue the rule?

4.1.1. The Oklahoma courts, in this case, might argue that the defendants of theft and embezzlement are both given due process of law by having the right to a jury trial. They might have, upon enacting this law, claimed that the crimes that fell under punishment by vasectomy, were distinguishable in severity or morality, and so could be punished differently under interpretation of the law.

4.2. How would the defendant argue the rule?

4.2.1. There is no equal protection under the 14th Amendment when different crimes of the same nature (theft) are punished differently. In the case of those punished for stealing, the vasectomy is forever; for those punished for embezzlement, the punishment is not long-lasting. The differentiation between these two crimes serves to discriminate between groups of people, thereby undermining (negating) the equal protection promised to all citizens under the 14th Amendment. Citizens are robbed of their due process of law.

5. Impact: what cases have cited the holding in Skinner v. Oklahoma and in what context?

5.1. One case that cites this decision: Buck v. Bell was not overturned because of Skinner v. Oklahoma because Buck v. Bell allowed the sterilization of mentally incompetent or unwell, which was a separate subject. However, the Skinner ruling did give pause to authorities because they were unsure of the legality of procedures.

5.2. In another case in 2002, the Skinner ruling was cited because Skinner upheld the right to not be federally sterilized. The CA "Appellate Court distinguished the case from Skinner v. Oklahoma because "the right to procreate while incarcerated and the right to be free from surgical sterilization by prison officials are two very different things." (Source: wikipedia)

6. Influence: why a healthcare professional should care about this topic/how it has changed way healthcare operates?

6.1. Healthcare professionals would no longer perform sterilizations on criminals of theft and not embezzlement. By upending the unconstitutional Oklahoma statute, healthcare professionals no longer has to perform federally mandated sterilizations that were: 1) unconstitutional under the 14th Amendment (no equal protection, discriminatory), 2) were cruel and unusual punishment under the 8th Amendment

7. Issue court is being called on to resolve?

7.1. The Supreme Court granted a petition for certiorari to determine the constitutionality, under the right to equal protection under the 14th Amendment, of Oklahoma's Criminal Habitual Sterilization Act

7.2. Does grouping different crimes of theft into categories punishable by federal sterilization or not constitute equal protection that the 14th Amendment should give?

7.3. Also at issue was: was this statute exacting cruel and unusual punishment, thereby violating the 8th Amendment?