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Kelli Dillon was only 24 when a surgeon at the Central California Women鈥檚 Facility in Chowchilla decided that she was not fit to be a parent and intentionally sterilized her without her consent. Dillon had sought medical attention for an abnormal pap smear and told the doctor that should he find cancerous cells, he could operate. After the procedure, Dillon intuitively felt that something was wrong, but the surgical team didn鈥檛 tell her she had been sterilized. Dillon fought the prison staff for over a year to gain access to her medical records, and only when a lawyer from Justice Now, an Oakland-based social justice legal advocacy organization, requested the records did Dillon learn the truth. 

In 2001, Dillon was one of 148 women incarcerated and living inside California鈥檚 state prisons who experienced medical abuse in the form of forced tubal ligations or total hysterectomies without their knowledge or consent and without required state approvals. A found that the state paid prison doctors $147,460 between 1997 and 2010 to sterilize incarcerated women, which one prison doctor said 鈥渋sn鈥檛 a huge amount of money鈥� when 鈥渃ompared to what you save in welfare paying for these unwanted children as they procreated more.鈥�

, medical teams inside California prisons could lawfully provide sterilizations that were deemed 鈥渕edically necessary鈥� and for the purposes of birth control if they received permission from the patient. But Dillon鈥檚 surgery, as well as dozens of others provided to young Black and Brown women, were t, according to a state audit. Dillon began to organize inside the women鈥檚 prison by collecting testimonials from other women the prison鈥檚 medical team had abused, and provided the personal accounts to staff at Justice Now that was laying the groundwork to petition for legislation that would ban the procedures in prisons.

Five years after she was forcibly sterilized, Dillon sued the state of California for damages, and her work helped to shape the scope of the Bill. 鈥淚 felt like it was this time for these truths to be revealed … these hidden evils that had been happening behind prison walls and institutional walls,鈥� Dillon says.

Dillon鈥檚 personal story and work, along with the efforts of Justice Now, were the subject of the 2020 film, . The documentary follows Dillon and the Justice Now team over a decade as they lobby lawmakers in Sacramento to prevent prison doctors from sterilizing and abusing more women. Belly of the Beast also chronicles the period of recovery, healing, and rebuilding Dillon navigated after she was allowed to return home. 

鈥淚t wasn’t until the making of the film and the showing of the film did my actual healing begin,鈥� Dillon says. 鈥淭hen I had to face what truly happened and the impact that it had on me and thousands of other women.鈥� 

An American Legacy

Twenty years after she was forcibly sterilized, Dillon reflects that the government鈥檚 actions are fundamentally about control: deciding who lives and who dies, who鈥檚 worthy of creating community, and who deserves to build a family. 鈥淭his is not just about the control of one鈥檚 body, but this is about people who are trying to control humanity,鈥� Dillon says. 鈥淭his is about people who are trying to control and determine the worth of a human life, and that is dangerous. And it鈥檚 diabolical.鈥�

Sterilization was found to be constitutional in a聽1927 Supreme Court case known as聽.聽The case has never been overturned, says Jasmine E. Harris, a professor of law at the University of California, Davis School of Law, though it鈥檚 not used as precedent.聽An 8-1 decision found that the institutionalization of Carrie Buck for 鈥渇eeblemindedness鈥� and her subsequent sterilization were both legal and justified. As Justice Oliver Wendell Holmes Jr. , 鈥淭hree generations of imbeciles are enough.鈥�

Though Buck was apparently institutionalized for an intellectual disability, Harris says that is false. Rather, Buck was a poor White woman鈥攕omeone politically disempowered and simultaneously dependent on the state government for social support services. Buck鈥檚 sterilization was a political move and a policy prototype motivated by a desire to 鈥減revent dependency on social welfare programs and draining of the public coffers,鈥� Harris says. Carrie Buck鈥檚 sterilization, as is often the case, was carried out at a government-run facility. 

Once other states saw that they could justify the medical abuse of women with this legal precedent, sterilizations increased dramatically in the 20th century. Some estimates say that at least were forcibly sterilized because of state laws and between 100,000 and 150,000. The uncertainty surrounding these totals is telling. 鈥淸Buck v. Bell] gave the green light to states to go ahead and actually create or incentivize sterilization of unwanted populations,鈥� Harris says, referring to those whose bodies and lives exist outside the norm of able-bodied White men, namely Black and Brown women.

During the height of this wave of eugenics by means of sterilization in the U.S., forced hysterectomies were so common in the Deep South that activist Fannie Lou Hamer coined the term 鈥溾�� to describe them. Thousands of poor Black women who had sought medical treatment at teaching hospitals, either because it cost less or because  

It wasn鈥檛 limited to the South, either. Between forcibly sterilized a documented 2,163 individuals, most of whom were Black. Scholars also documented a direct link between in the state. 

A 1970 federal law known as the allowed the Indian Health Service, which is run through the Department of Interior, to sterilize Native women and girls, often by means of . Native activists and scholars estimate that the act paved the way for the IHS to sterilize and girls between the ages of 15 and 44 in the 1970s. 

The longest running and most expansive eugenics policy was enacted in California, where between 1909 and 1979 at least most of them women. 

Organizing Against Medical Abuse 

The legacy of 20th century sterilizations continues today. In September 2020, that the Irwin County Detention Center in Georgia had forcibly sterilized at least five women in the custody of Immigrations and Customs Enforcement, though the true number of women who have suffered this medical abuse is unknown. 

Project South, a Georgia-based grassroots organization working to eliminate poverty and genocide, on behalf of the detained individuals, arguing that the human rights abuses in the detention center range from the highly publicized hysterectomies to a lack of precautions to mitigate the spread of COVID-19. Since Project South filed the complaint, at least 57 women have come forward to say they experienced medical abuse, says Azadeh Shahshahani, Project South鈥檚 legal and advocacy director.  

In response, congressional legislators toured the Irwin facilities, called for an investigation, and suggested that the ICE detention facilities be reformed. 鈥淚t’s good to see that the issue of medical abuse against women鈥檚 bodies is finally getting the attention that it deserves,鈥� Shahshahani says. But she says that there鈥檚 a real danger in what will likely be a slow initiation of incremental change. 鈥淲hat [we] really need is for the facility to be shut down as soon as possible and for the women to be free,鈥� Shahshahani says. 鈥淭his place [cannot] be reformed.鈥�

True to the legacy of Buck v. Bell, the medical abuse of Black and Brown immigrants is linked with the physicality of the institution itself and the federal government鈥檚 commitment to bureaucratic process over justice, Shahshahani says. The women represented in the complaint are 鈥渋n U.S. government custody as well as the custody of these private prison corporations,鈥� Shahshahani says, adding that the private corporation that owns the facility鈥擫aSalle Corrections鈥攎akes money off of the incarceration of women who lack permanent residency status. 鈥淲omen have been dehumanized,鈥� Shahshahani says. 鈥淭hey’re being treated as tools in order for these private prison corporations to make profit.鈥�

Each instance of medical abuse of women creates a new wave of awareness in the United States of the fact that Buck v. Bell was never overturned, further illustrating the need for legislative change and reparative policy, advocates say. 

On the West Coast, California Latinas for Reproductive Justice is working to secure legislative change for victims of the state鈥檚 sterilization efforts between 1909 and 1979. The reproductive justice organization is shepherding the proposed compensation program through the California legislature. If it passes, it will be the state鈥檚 first legislative motion to provide monetary compensation to victims of its long-standing eugenics practice, says Laura Jim茅nez, executive director of CLRJ. 鈥淲e’re currently approaching the governor’s office and the heads of the budget on both sides of the house in California and requesting that they include this request into their next year budget proposals,鈥� Jim茅nez says. In stewarding this legislation, California Latinas for Reproductive Justice is following the lead of and , which established their own compensation programs in 2013 and 2015, respectively. 

Many victims of California鈥檚 unjust practices have died, but those who are eligible will receive the state鈥檚 first financial compensation for this kind of medical abuse. Thus far, the apologies have not carried this kind of weight. In 2003, around the same time that California鈥檚 prisons sterilized women like Dillon, then-Gov. Gray Davis to the 20th century victims of sterilization and their family members. 

Jim茅nez says that no financial payment could ever compensate holistically for medical abuse, but she says that 鈥渙ur systems talk to each other in money,鈥� and that the 鈥渟ymbolic gesture of regret from the state鈥� would mark a first step in addressing California鈥檚 problematic history. 鈥淚 think that putting money behind it makes it sincere,鈥� Jim茅nez says. 鈥淚t makes it more likely that the state will think twice about violating the human rights of people that are vulnerable and within its care.鈥�

CORRECTION: This article was updated at 8:17p.m. on Feb. 24, 2021, to clarify that sterilization is still considered constitutional, rather than legal.聽Read our corrections policy here.