Skinner v. Oklahoma Case Brief

Facts of the case

Oklahoma’s Criminal Sterilization Act of 1935 allowed the state to sterilize a person who had been convicted three or more times of crimes amounting to felonies involving moral turpitude.After his third conviction, Skinner was determined to be a habitual offender and ordered to be sterilized. He argued that the law violated the Fourteenth Amendment.

Why is the case important?

Under Oklahoma law, a person convicted a third time of certain specified crimes involving “moral turpitude” received the punishment of sterilization. Persons convicted a third time of other similar crimes were not. The constitutionality of this distinction was brought into question.

Question

Was the Act, calling for the sterilization of certain multiple offenders but not others, in violation of the Equal Protection Clause of the Fourteenth Amendment of the United States Constitution (Constitution)?

ANSWER

No. Supreme Court of Oklahoma ruling reversed.
Justice William Douglas (J. Douglas) notes that sterilization of habitual offenders in no way guarantees that new offenders will not be born. Furthermore, there is no guarantee that habitual offenders would spawn offenders themselves.
J. Douglas cannot justify the distinction between larceny (involving moral turpitude) and embezzlement (not involving moral turpitude) in the eyes of the statute. This is clear discrimination in J. Douglas’s view. In terms of fines and imprisonment the crimes are identical to the State. Only when it comes to sterilization do the crimes differ. As such, equal protection is violated.
Concurrence. Chief Justice Harlan Stone (J. Stone) concurs in the judgment, but rests his decision on due process grounds, arguing that the invasion of personal liberty is too great.

CONCLUSION

The court held that the act failed to meet the requirements of the equal protection clause of the Fourteenth Amendment. The court found that defendant was convicted of larceny and that the act treated larceny and embezzlement, intrinsically the same crime and punishable in the same manner, the same except for the sterilization provision. The equal protection clause did not prevent a legislature from recognizing degrees of evil, and the constitution did not require things different in fact or opinion to be treated in law as though they were the same. However, where legislation laid an unequal hand on those who had committed the same quality of offense, the equal protection clause would be a formula of empty words if such conspicuously artificial lines could be drawn. The crimes of larceny and embezzlement rated the same terms of fines and imprisonment, but when it came to sterilization the pains and penalties of the law were different, which made for invidious discrimination against groups of individuals in violation of the constitutional guaranty of just and equal laws.

  • Advocates: –
  • Petitioner: Skinner
  • Respondent: Oklahoma ex rel. Williamson
  • DECIDED BY:Stone Court
  • Location: –
Citation: 316 US 535 (1942)
Argued: May 6, 1942
Decided: Jun 1, 1942
Skinner v. Oklahoma Case Brief